UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-cv-61677

GIANNI VERSACE S.R.L., and 

J. CHOO LIMITED,

Plaintiffs, 

vs. 

THE INDIVIDUALS, BUSINESS ENTITIES, 

AND UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE “A,” 

Defendants. 

_____________________________________/ 

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF 

Plaintiffs, Gianni Versace S.r.l. (“Versace”) and J. Choo Limited (“Jimmy Choo”) 

(collectively “Plaintiffs”)1 hereby sue Defendants, the Individuals, Business Entities, and 

Unincorporated Associations identified on Schedule “A” (collectively “Defendants”). 

Defendants are promoting, selling, offering for sale and distributing goods bearing and/or using 

counterfeits and confusingly similar imitations of Plaintiffs’ trademarks within this district 

through various Internet based e-commerce stores operating via marketplace websites, image 

hosting and social media websites, and fully interactive commercial Internet websites operating 

under the seller identities and domain names set forth on Schedule “A” hereto (the “Seller IDs 

and Subject Domain Names”). In support of their claims, Plaintiffs allege as follows: 

JURISDICTION AND VENUE 

1. This is an action for federal trademark counterfeiting and infringement, false

designation of origin, common law unfair competition, and common law trademark infringement 

1

 The Plaintiffs, Versace and Jimmy Choo, are related ultimate subsidiaries of Capri Holdings 

Limited, which is a global leader in luxury lifestyle apparel, footwear and accessories. 

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pursuant to 15 U.S.C. §§ 1114, 1116, and 1125(a), The All Writs Act, 28 U.S.C. § 1651(a), and 

Florida’s common law. Accordingly, this Court has subject matter jurisdiction over this action 

pursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338. This Court has supplemental 

jurisdiction pursuant to 28 U.S.C. § 1367 over Plaintiffs’ state law claims because those claims 

are so related to the federal claims that they form part of the same case or controversy. 

2. Defendants are subject to personal jurisdiction in this district, because they direct 

business activities toward and conduct business with consumers throughout the United States, 

including within the State of Florida and this district, through at least the Internet based ecommerce stores2

 and the fully interactive commercial Internet websites accessible in Florida 

operating under their Seller IDs and the Subject Domain Names. Alternatively, Defendants are 

subject to personal jurisdiction in this district pursuant to Federal Rule of Civil Procedure 4(k)(2) 

because (i) Defendants are not subject to jurisdiction in any state’s court of general jurisdiction; 

and (ii) exercising jurisdiction is consistent with the United States Constitution and laws. 

3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 since Defendants are, 

upon information and belief, aliens who are engaged in infringing activities and causing harm 

within this district by advertising, offering to sell, selling, and/or shipping infringing products 

into this district. 

2

 Some Defendants use their Seller IDs or Subject Domain Name in tandem with electronic 

communication via private messaging applications or services to complete their offer and sale of 

counterfeit products bearing the Plaintiffs’ registered trademarks. Specifically, consumers can 

browse listings of the Plaintiffs’ branded products online via the Defendants’ Seller IDs and are 

then ultimately directed to send inquiries, exchange data, and complete purchases via electronic 

communication with those Defendants. These Defendants operate via websites, third-party social 

media or image hosting websites in tandem with the above-described electronic communication 

to create an interconnected ecosystem which functions as an online marketplace operation and ecommerce store. 

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THE PLAINTIFFS 

4. Capri Holdings Limited is a publicly held company incorporated in the British

Virgin Islands with its principal place of business located at 33 Kingsway, London, WC2B 6TP, 

UK. Capri Holdings Limited is the parent company of Plaintiffs Gianni Versace S.r.l. and J.Choo 

Limited. 

5. Gianni Versace S.r.l. is an Italian Corporation with its principal place of business

located at Via Manzoni Nr. 38, 20121, Milan, Italy. Versace operates boutiques throughout the 

world, including within this district. Versace is, in part, engaged in the business of manufacturing 

and distributing throughout the world, including within this district, a variety of high-quality 

goods under multiple world-famous common law and federally registered trademarks, as 

discussed in Paragraph 17 below, and identified in Schedule “B” hereto. Versace offers for sale 

and sells its trademarked goods within this district. Defendants, through the offers for sale and 

sale of counterfeit and infringing Versace branded products, are directly and unfairly competing 

with Plaintiffs’ economic interests in the State of Florida and causing Versace harm and damages 

within this jurisdiction. 

6. J. Choo Limited is a United Kingdom Private Limited Company with its principal

place of business located at 10 Howick Place London SW1P 1GW, UK. Jimmy Choo operates 

boutiques throughout the world, including within this district. Jimmy Choo is, in part, engaged in 

the business of manufacturing and distributing throughout the world, including within this 

district, a variety of high-quality goods under multiple world-famous common law and federally 

registered trademarks, as discussed in Paragraph 26 below, and identified in Schedule “C” 

hereto. Jimmy Choo offers for sale and sells its trademarked goods within this district. 

Defendants, through the offers for sale and sale of counterfeit and infringing Jimmy Choo 

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branded products, are directly and unfairly competing with Plaintiffs’ economic interests in the 

State of Florida and causing Jimmy Choo harm within this jurisdiction. 

7. Like many other famous trademark owners in the luxury goods market, Plaintiffs 

suffer ongoing daily and sustained violations of their trademark rights at the hands of 

counterfeiters and infringers, such as Defendants herein, who wrongfully reproduce and 

counterfeit Plaintiffs’ trademarks for the twin purposes of (i) duping and confusing the 

consuming public and (ii) earning substantial profits across their e-commerce stores and 

websites. The natural and intended byproduct of Defendants’ actions is the erosion and 

destruction of the goodwill associated with the Plaintiffs’ respective names and associated 

trademarks and the destruction of the legitimate market sector in which they operate. 

8. In order to combat the indivisible harm caused by the combined actions of 

Defendants and others engaging in similar conduct, each year Plaintiffs expend significant 

monetary resources in connection with trademark enforcement efforts. The exponential growth 

of counterfeiting over the Internet has created an environment that requires companies, such as 

Plaintiffs, to expend significant time and money across a wide spectrum of efforts, in order to 

protect both consumers and themselves from the ill effects of confusion and the erosion of the 

goodwill connected to the Plaintiffs’ respective brands. 

THE DEFENDANTS 

9. Defendants are individuals, business entities of unknown makeup, or 

unincorporated associations, each of whom, upon information and belief, either reside and/or 

operate in foreign jurisdictions, or redistribute products from the same or similar sources in those 

locations, and/or ship their goods from the same or similar sources in those locations to shipping 

and fulfillment centers within the United States to redistribute their products from those 

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locations. Defendants have the capacity to be sued pursuant to Federal Rule of Civil Procedure 

17(b). Defendants purposefully target their business activities toward consumers throughout the 

United States, including within this district, through the operation of commercial Internet based 

e-commerce stores via Internet marketplace websites under the Seller IDs and commercial 

Internet websites under the Subject Domain Names. 

10. Upon information and belief, Defendants use aliases in conjunction with the 

operation of their businesses. Defendants are directly and personally contributing to, inducing, 

and engaging in the sale of counterfeit branded products as alleged herein, often times as 

partners, co-conspirators, and/or suppliers. 

11. Defendants are the past and present controlling forces behind the sale of products 

using counterfeits and infringements of Plaintiffs’ respective trademarks as described herein. 

12. Defendants directly engage in unfair competition with Plaintiffs by advertising, 

offering for sale, and selling goods using counterfeits and infringements of one or more of 

Plaintiffs’ respective trademarks to consumers within the United States and this district through 

Internet based e-commerce stores using, at least, the Seller IDs and Subject Domain Names, as 

well as additional names, e-commerce stores, seller identification aliases, domain names, or 

websites not yet known to Plaintiffs. Defendants have purposefully directed some portion of their 

illegal activities towards consumers in the State of Florida through the advertisement, offer to 

sell, sale, and/or shipment of counterfeit and infringing branded versions of Plaintiffs’ goods into 

the State. 

13. Defendants have registered, established or purchased, and maintained their Seller 

IDs and Subject Domain Names. Defendants may have engaged in fraudulent conduct with 

respect to the registration of the Seller IDs and Subject Domain Names by providing false and/or 

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misleading information to the Internet based e-commerce platforms or domain registrars where 

they offer to sell and/or sell during the registration or maintenance process related to their 

respective Seller ID and Subject Domain Name. Many Defendants have registered and 

maintained some of the Seller IDs or Subject Domain Names for the purpose of engaging in 

illegal counterfeiting and/or infringing activities. 

14. Defendants will likely continue to register or acquire new seller identification 

aliases, user names, photo albums, private messaging accounts, domain names, and other aliases, 

as well as related payment accounts, for the purpose of selling and/or offering for sale goods 

bearing and using counterfeit and confusingly similar imitations of one or more of Plaintiffs’ 

trademarks unless preliminarily and permanently enjoined. 

15. Defendants use their Internet-based businesses to infringe the intellectual property 

rights of Plaintiffs and others. 

16. Defendants’ business names, i.e., the Seller IDs and Subject Domain Names, 

associated payment accounts, and any other alias seller identification names and domain names 

used in connection with the sale of counterfeit and infringing goods using one or more of 

Plaintiffs’ trademarks are essential components of Defendants’ online activities and are one of 

the means by which Defendants further their counterfeiting and infringement scheme and cause 

harm to Plaintiffs. Moreover, Defendants are using Plaintiffs’ famous brand names and 

associated trademarks to drive Internet consumer traffic to their e-commerce stores or websites 

operating under the Seller IDs and Subject Domain Names, thereby increasing the value of the 

Seller IDs and Subject Domain Names, and decreasing the size and value of Plaintiffs’ legitimate 

marketplace and intellectual property rights at Plaintiffs’ expense. 

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COMMON FACTUAL ALLEGATIONS 

Plaintiffs’ Business and Trademark Rights 

17. Versace is the owner of all rights in and to the trademarks identified on Schedule

“B” hereto, which are valid and registered on the Principal Register of the United States Patent 

and Trademark Office (collectively the “Versace Marks”). The Versace Marks are used in

connection with the manufacture and distribution of high-quality goods in the categories 

identified above. True and correct copies of the Certificates of Registration for the Versace 

Marks are attached hereto as Composite Exhibit “1.” 

18. The Versace Marks have been used in interstate commerce to identify and

distinguish Versace’s high-quality goods for an extended period of time.

19. The Versace Marks have been used by Versace long prior in time to Defendants’

use of copies of those Marks. The Versace Marks have never been assigned or licensed to any of 

the Defendants in this matter. 

20. The Versace Marks are symbols of Versace’s quality, reputation and goodwill and

have never been abandoned. Versace has carefully monitored and policed the use of the Versace 

Marks. 

21. The Versace Marks are well known and famous and have been for many years.

Versace expends substantial resources developing, advertising and otherwise promoting the 

Versace Marks. The Versace Marks qualify as famous marks as that term is used in 15 U.S.C. 

§1125(c)(1).

22. Further, Versace extensively uses, advertises, and promotes the Versace Marks in

the United States in association with the sale of high-quality goods. Versace has spent millions of 

dollars promoting the Versace Marks and products bearing the Versace Marks. In recent years, 

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annual sales of products bearing the Versace Marks have totaled in the many millions of dollars

within the United States.

23. As a result of Versace’s efforts, members of the consuming public readily identify

merchandise bearing or sold under the Versace Marks as being high-quality goods sponsored and 

approved by Versace. 

24. Accordingly, the Versace Marks have achieved secondary meaning as identifiers

of high-quality goods. 

25. Genuine goods bearing the Versace Marks are widely legitimately advertised and

promoted by Versace, its authorized distributors, and unrelated third parties via the Internet. 

Visibility on the Internet, particularly via Internet search engines such as Google, Yahoo!, and 

Bing is important to Versace’s overall marketing and consumer education efforts. Thus, Versace 

expends significant monetary resources on Internet marketing and consumer education, including 

search engine optimization (“SEO”) and search engine marketing (“SEM”) strategies. Those 

strategies allow Versace and its authorized retailers to fairly and legitimately educate consumers 

about the value associated with the Versace brand and the goods sold thereunder. Similarly,

Defendants’ individual seller stores and websites are indexed on search engines and compete 

directly with Versace for space and consumer attention in search results. 

26. Jimmy Choo is the owner of all rights in and to the trademarks identified on

Schedule “C” hereto, which are valid and registered on the Principal Register of the United 

States Patent and Trademark Office (collectively the “Jimmy Choo Marks”). The Jimmy Choo 

Marks are used in connection with the manufacture and distribution of high-quality goods in the 

categories identified above. True and correct copies of the Certificates of Registration for the 

Jimmy Choo Marks are attached hereto as Composite Exhibit “2.” 

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27. The Jimmy Choo Marks have been used in interstate commerce to identify and 

distinguish Jimmy Choo’s high-quality goods for an extended period of time. 

28. The Jimmy Choo Marks have been used by Jimmy Choo long prior in time to 

Defendants’ use of copies of those Marks. The Jimmy Choo Marks have never been assigned or 

licensed to any of the Defendants in this matter. 

29. The Jimmy Choo Marks are symbols of Jimmy Choo’s quality, reputation and 

goodwill and have never been abandoned. Jimmy Choo has carefully monitored and policed the 

use of the Jimmy Choo Marks. 

30. The Jimmy Choo Marks are well known and famous and have been for many 

years. Jimmy Choo has expended substantial time, money and other resources developing, 

advertising and otherwise promoting the Jimmy Choo Marks. The Jimmy Choo Marks qualify as 

famous marks as that term is used in 15 U.S.C. §1125(c)(1). 

31. Further, Jimmy Choo has extensively used, advertised, and promoted the Jimmy 

Choo Marks in the United States in association with the sale of high-quality goods. Jimmy Choo 

has spent millions of dollars promoting the Jimmy Choo Marks and products bearing the Jimmy 

Choo Marks. In recent years, annual sales of products bearing the Jimmy Choo Marks have 

totaled in the many millions of dollars within the United States. 

32. As a result of Jimmy Choo’s efforts, members of the consuming public readily 

identify merchandise bearing or sold under the Jimmy Choo Marks as being high-quality goods 

sponsored and approved by Jimmy Choo. 

33. Accordingly, the Jimmy Choo Marks have achieved secondary meaning as 

identifiers of high-quality goods. 

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34. Genuine goods bearing the Jimmy Choo Marks are widely legitimately advertised 

and promoted by Jimmy Choo, its authorized distributors, and unrelated third parties via the 

Internet. Visibility on the Internet, particularly via Internet search engines such as Google, 

Yahoo!, and Bing is important to Jimmy Choo’s overall marketing and consumer education 

efforts. Thus, Jimmy Choo expends significant monetary resources on Internet marketing and 

consumer education, including search engine optimization (“SEO”) and search engine marketing 

(“SEM”) strategies. Those strategies allow Jimmy Choo and its authorized retailers to fairly and 

legitimately educate consumers about the value associated with the Jimmy Choo brand and the 

goods sold thereunder. Similarly, Defendants’ individual seller stores and websites are indexed 

on search engines and compete directly with Jimmy Choo for space and consumer attention in 

search results. 

Defendants’ Infringing Activities

35. Defendants are each promoting and advertising, distributing, offering for sale, 

and/or selling goods in interstate commerce using counterfeit and confusingly similar imitations 

of one or more of the Versace Marks or the Jimmy Choo Marks (the “Counterfeit Goods”) 

through at least the Internet based e-commerce stores or commercial Internet websites operating 

under the Seller IDs and Subject Domain Names. Specifically, Defendants are using the Versace 

Marks or the Jimmy Choo Marks (collectively, the “Plaintiffs’ Marks”) to initially attract online 

consumers and drive them to Defendants’ e-commerce stores operating under the Seller IDs and 

Subject Domain Names. Defendants are each using identical copies of one or more Plaintiffs’ 

Marks for different quality goods. Plaintiffs have used their respective Marks extensively and 

continuously before Defendants began offering counterfeit and confusingly similar imitations of 

Plaintiffs’ merchandise. 

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36. Defendants’ Counterfeit Goods are of a quality substantially different than that of 

Plaintiffs’ respective genuine goods. Defendants are actively using, promoting and otherwise 

advertising, distributing, selling and/or offering for sale substantial quantities of their Counterfeit 

Goods with the knowledge and intent that such goods will be mistaken for the genuine high 

quality goods offered for sale by Plaintiffs despite Defendants’ knowledge that they are without 

authority to use Plaintiffs’ Marks. The net effect of Defendants’ actions is likely to cause 

confusion of consumers, at the time of initial interest, sale, and in the post sale setting, who will 

believe all of Defendants’ goods offered for sale in or through Defendants’ e-commerce stores 

and websites are genuine goods originating from, associated with, and/or approved by Plaintiffs. 

37. Defendants advertise their e-commerce stores and websites, including their 

Counterfeit Goods offered for sale, to the consuming public via e-commerce stores on, at least, 

one Internet marketplace platform, social media website and/or image hosting website using, at 

least, the Seller IDs and/or commercial Internet websites operating under the Subject Domain 

Names. In so advertising these stores and goods, Defendants improperly and unlawfully use one 

or more of Plaintiffs’ Marks without Plaintiffs’ permission. 

38. As part of their overall unlawful scheme, Defendants are, upon information and 

belief, concurrently employing and benefitting from substantially similar, advertising and 

marketing strategies based, in large measure, upon an illegal use of counterfeits and 

infringements of Plaintiffs’ Marks. Specifically, Defendants are using counterfeits and 

infringements of one or more of Plaintiffs’ famous names or Plaintiffs’ Marks in order to make 

their e-commerce stores and websites selling illegal goods appear more relevant and attractive to 

consumers searching for both Plaintiffs’ and non-Plaintiffs’ goods and information online. By 

their actions, Defendants are contributing to the creation and maintenance of an illegal 

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marketplace operating in parallel to the legitimate marketplace for Plaintiffs’ respective, genuine 

goods. Defendants are causing individual, concurrent and indivisible harm to Plaintiffs and the 

consuming public by (i) depriving Plaintiffs and other third parties of their right to fairly 

compete for space online and within search engine results and reducing the visibility of 

Plaintiffs’ genuine goods on the World Wide Web, (ii) causing an overall degradation of the 

value of the goodwill associated with Plaintiffs’ Marks, and (iii) increasing Plaintiffs’ overall 

cost to market their goods and educate consumers about their brands via the Internet. 

39. Defendants are concurrently conducting and targeting their counterfeiting and 

infringing activities toward consumers and likely causing unified harm within this district and 

elsewhere throughout the United States. As a result, Defendants are defrauding Plaintiffs and the 

consuming public for Defendants’ own benefit. 

40. At all times relevant hereto, Defendants have full knowledge of Plaintiffs’ 

respective ownership of Plaintiffs’ Marks, including their respective, exclusive rights to use and 

license such intellectual property and the goodwill associated therewith. 

41. Defendants’ use of Plaintiffs’ respective Marks, including the promotion and 

advertisement, reproduction, distribution, sale and offering for sale of their Counterfeit Goods, is 

without Plaintiffs’ consent or authorization. 

42. Defendants are engaging in the above-described illegal counterfeiting and 

infringing activities knowingly and intentionally or with reckless disregard or willful blindness to 

Plaintiffs’ rights for the purpose of trading on Plaintiffs’ goodwill and reputations. If Defendants’ 

intentional counterfeiting and infringing activities are not preliminarily and permanently 

enjoined by this Court, Plaintiffs and the consuming public will continue to be harmed. 

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43. Defendants’ above identified infringing activities are likely to cause confusion, 

deception, and mistake in the minds of consumers before, during and after the time of purchase. 

Moreover, Defendants’ wrongful conduct is likely to create a false impression and deceive 

customers, the public, and the trade into believing there is a connection or association between 

Plaintiffs’ respective genuine goods and Defendants’ Counterfeit Goods, which there is not. 

44. Given the visibility of Defendants’ various e-commerce stores, photo albums, and 

websites and the similarity of their actions, it is clear Defendants are either affiliated, or at a 

minimum, cannot help but know of each other’s existence and the unified harm likely to be 

caused to Plaintiffs and the overall consumer market in which they operate because of 

Defendants’ concurrent actions. 

45. Although some Defendants may be physically acting independently, they may 

properly be deemed to be acting in concert because the combined force of their actions serves to 

multiply the harm caused to Plaintiffs. 

46. Upon information and belief, Defendants’ payment and financial accounts, 

including but not limited to those specifically set forth on Schedule “A,” are being used by 

Defendants to accept, receive, and deposit profits from Defendants’ trademark counterfeiting and 

infringing and unfairly competitive activities connected to their Seller IDs and Subject Domain 

Names, and any other alias seller identification names, domain names, or websites being used 

and/or controlled by them. 

47. Further, Defendants are likely to transfer or secret their assets to avoid payment of 

any monetary judgment awarded to Plaintiffs. 

48. Plaintiffs have no adequate remedy at law. 

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49. Plaintiffs are suffering irreparable injury and have suffered substantial damages as 

a result of Defendants’ unauthorized and wrongful use of Plaintiffs’ Marks. If Defendants’ 

counterfeiting and infringing, and unfairly competitive activities are not preliminarily and 

permanently enjoined by this Court, Plaintiffs and the consuming public will continue to be 

harmed. 

50. The harm and damages sustained by Plaintiffs have been directly and proximately 

caused by Defendants’ wrongful reproduction, use, advertisement, promotion, offers to sell, and 

sale of their Counterfeit Goods. 

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT 

PURSUANT TO § 32 OF THE LANHAM ACT (15 U.S.C. § 1114) 

51. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 50 above. 

52. This is an action for trademark counterfeiting and infringement against 

Defendants based on their use of counterfeit and confusingly similar imitations of Plaintiffs’ 

Marks in commerce in connection with the promotion, advertisement, distribution, offering for 

sale and sale of the Counterfeit Goods. 

53. Defendants are promoting and otherwise advertising, selling, offering for sale, 

and distributing goods bearing and/or using counterfeits and/or infringements of one or more of 

Plaintiffs’ Marks. Defendants are continuously infringing and inducing others to infringe 

Plaintiffs’ Marks by using one or more of them to advertise, promote, offer to sell, and sell 

counterfeit and infringing versions of Plaintiffs’ branded goods. 

54. Defendants’ concurrent counterfeiting and infringing activities are likely to cause 

and actually are causing confusion, mistake, and deception among members of the trade and the 

general consuming public as to the origin and quality of Defendants’ Counterfeit Goods. 

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55. Defendants’ unlawful actions have caused and are continuing to cause 

unquantifiable damages to Plaintiffs and are unjustly enriching Defendants with profits at 

Plaintiffs’ expense. 

56. Defendants’ above-described unlawful actions constitute counterfeiting and 

infringement of Plaintiffs’ Marks in violation of Plaintiffs’ rights under § 32 of the Lanham Act, 

15 U.S.C. § 1114. 

57. Plaintiffs have each suffered and will continue to suffer irreparable injury and 

damages due to Defendants’ above-described activities if Defendants are not preliminarily and 

permanently enjoined. Additionally, Defendants will continue to wrongfully profit from their 

illegal activities. 

COUNT II - FALSE DESIGNATION OF ORIGIN 

PURSUANT TO § 43(a) OF THE LANHAM ACT (15 U.S.C. § 1125(a)) 

58. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 50 above. 

59. Defendants’ Counterfeit Goods offered for sale and sold using copies of at least 

one of Plaintiffs’ Marks have been widely advertised and offered for sale throughout the United 

States at least one Internet marketplace website, social media or imaging hosting website, or 

fully interactive commercial Internet website. 

60. Defendants’ Counterfeit Goods offered for sale and sold using copies of at least 

one of the Plaintiffs’ Marks are virtually identical in appearance to Plaintiffs’ respective, genuine 

goods. However, Defendants’ Counterfeit Goods are different in quality. Accordingly, 

Defendants’ activities are likely to cause confusion in the trade and among consumers as to at 

least the origin or sponsorship of their Counterfeit Goods. 

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61. Defendants have used in connection with their advertisement, offer for sale, and 

sale of their Counterfeit Goods, false designations of origin and false descriptions and 

representations, including words or other symbols and trade dress, which tend to falsely describe 

or represent such goods and have caused such goods to enter commerce in the United States with 

full knowledge of the falsity of such designations of origin and such descriptions and 

representations, all to Plaintiffs’ detriment. 

62. Defendants have each authorized infringing uses of one or more of Plaintiffs’ 

Marks in Defendants’ advertisement and promotion of their counterfeit and infringing branded 

goods. Defendants have misrepresented to members of the consuming public that the 

Counterfeit Goods being advertised and sold by them are genuine, non-infringing goods. 

63. Additionally, Defendants are using counterfeits and infringements of one or more 

of Plaintiffs’ Marks in order to unfairly compete with Plaintiffs and others for space within 

organic and paid search engine and social media results, thereby jointly depriving Plaintiffs of a 

valuable marketing and educational tool which would otherwise be available to Plaintiffs and 

reducing the visibility of Plaintiffs’ respective, genuine goods on the World Wide Web and 

across social media platforms. 

64. Defendants’ above-described actions are in violation of Section 43(a) of the 

Lanham Act, 15 U.S.C. §1125(a). 

65. Plaintiffs have no adequate remedy at law, and have sustained both individual and 

indivisible injury and damage caused by Defendants’ concurrent conduct. Absent an entry of an 

injunction by this Court, Defendants will continue to wrongfully reap profits and each Plaintiff 

will continue to suffer irreparable injury to their respective goodwill and business reputations, as 

well as monetary damages. 

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COUNT III - COMMON LAW UNFAIR COMPETITION. 

66. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 50 above. 

67. This is an action against Defendants based on their promotion, advertisement, 

distribution, sale and/or offering for sale of goods bearing and/or using marks that are virtually 

identical to one or more of Plaintiffs’ Marks in violation of Florida’s common law of unfair 

competition. 

68. Specifically, Defendants are promoting and otherwise advertising, selling, 

offering for sale and distributing using or bearing counterfeits and infringements of one or more 

of the Plaintiffs’ Marks. Defendants are also each using counterfeits and infringements of one 

more of the Plaintiffs’ Marks to unfairly compete with Plaintiffs and others for (1) space in 

search engine and social media results across an array of search terms and (2) visibility on the 

World Wide Web. 

69. Defendants’ infringing activities are likely to cause and are causing confusion, 

mistake and deception among consumers as to the origin and quality of Defendants’ e-commerce 

stores as a whole and all products sold therein by their use of Plaintiffs’ Marks. 

70. Plaintiffs have no adequate remedy at law and are suffering irreparable injury and 

damages as a result of Defendants’ actions. Moreover, Defendants are unjustly profiting from 

those actions. 

COUNT IV - COMMON LAW TRADEMARK INFRINGEMENT

71. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 50 above.

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72. Plaintiffs are the respective owners of all common law rights in and to the 

Plaintiffs’ respective Marks. 

73. This is an action for common law trademark infringement against Defendants 

based on their promotion, advertisement, offering for sale, and sale of their Counterfeit Goods 

using at least one of Plaintiffs’ Marks. Plaintiffs are the owners of all common law rights in and 

to Plaintiffs’ respective Marks. 

74. Specifically, each Defendant is promoting, and otherwise advertising, distributing, 

offering for sale, and selling goods using and/or bearing infringements of one or more of 

Plaintiffs’ Marks.

75. Defendants’ infringing activities are likely to cause and are causing confusion, 

mistake and deception among consumers as to the origin and quality of Defendants’ Counterfeit 

Goods using Plaintiffs’ Marks.

76. Plaintiffs have no adequate remedy at law and are suffering damages and 

irreparable injury because of Defendants’ actions. Moreover, Defendants are unjustly profiting 

from those actions.

PRAYER FOR RELIEF 

77. WHEREFORE, Plaintiffs demand judgment on all Counts of this Complaint and 

an award of equitable relief and monetary relief against Defendants as follows: 

a. Entry of temporary, preliminary, and permanent injunctions pursuant to 15 

U.S.C. § 1116, 28 U.S.C. § 1651(a), The All Writs Act, and Federal Rule of Civil Procedure 65 

enjoining Defendants, their agents, representatives, servants, employees, and all those acting in 

concert or participation therewith, from manufacturing or causing to be manufactured, importing, 

advertising or promoting, distributing, selling or offering to sell their Counterfeit Goods; from 

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infringing, counterfeiting, or diluting the Plaintiffs’ Marks; from using the Plaintiffs’ Marks, or 

any mark or trade dress similar thereto, in connection with the sale of any unauthorized goods; 

from using any logo, trade name or trademark or trade dress that may be calculated to falsely 

advertise the services or goods of Defendants as being sponsored by, authorized by, endorsed by, 

or in any way associated with Plaintiffs; from falsely representing themselves as being connected 

with Plaintiffs, through sponsorship or association, or engaging in any act that is likely to falsely 

cause members of the trade and/or of the purchasing public to believe any goods or services of 

Defendants, are in any way endorsed by, approved by, and/or associated with Plaintiffs; from 

using any reproduction, counterfeit, infringement, copy, or colorable imitation of the Plaintiffs’ 

Marks in connection with the publicity, promotion, sale, or advertising of any goods sold by 

Defendants; from 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 Defendants’ goods as being those of Plaintiffs, or in any way endorsed by Plaintiffs 

and from offering such goods in commerce; from engaging in search engine optimization 

strategies using colorable imitations of Plaintiffs’ name or trademarks; and from otherwise 

unfairly competing with Plaintiffs. 

b. Entry of a temporary restraining order, as well as preliminary and 

permanent injunctions pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and the Court’s 

inherent authority, enjoining Defendants and all third parties with actual notice of an injunction 

issued by the Court from participating in, including providing financial services, technical 

services or other support to, Defendants in connection with the sale and distribution of nongenuine goods bearing and/or using counterfeits of the Plaintiffs’ Marks. 

Case 0:22-cv-61677-AHS Document 1 Entered on FLSD Docket 09/08/2022 Page 19 of 35
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c. Entry of an order pursuant to 15 U.S.C. § 1116, 28 U.S.C. § 1651(a), The 

All Writs Act, and the Court’s inherent authority, that upon Plaintiffs’ request, Defendants and 

the top level domain (TLD) Registry for each of the Subject Domain Names, and any other 

domains used by Defendants, or their administrators, including backend registry operators or 

administrators, place the Subject Domain Names on Registry Hold status for the remainder of the 

registration period for any such domain name, thus removing them from the TLD zone files 

which link the Subject Domain Names, and any other domain names being used and/or 

controlled by Defendants to engage in the business of marketing, offering to sell, and/or selling 

goods bearing counterfeits and infringements of the Plaintiffs’ Marks, to the IP addresses where 

the associated websites are hosted. 

d. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, canceling for the life of the current registration or, at Plaintiffs’ 

election, transferring the Subject Domain Names and any other domain names used by 

Defendants to engage in their counterfeiting of the Plaintiffs’ Marks at issue to Plaintiffs’ control 

so they may no longer be used for unlawful purposes. 

e. Entry of an order pursuant to 15 U.S.C. § 1116 and the Court’s inherent 

authority, requiring Defendants, their agent(s) or assign(s), to assign all rights, title, and interest, 

to their Subject Domain Name(s) and any other domain names used by Defendants to Plaintiffs 

and, if within five (5) days of entry of such order Defendants fail to make such an assignment, 

the Court order the act to be done by another person appointed by the Court at Defendants’ 

expense, such as the Clerk of Court, pursuant to Federal Rule of Civil Procedure 70(a). 

f. Entry of an order pursuant to 15 U.S.C. § 1116 and the Court’s inherent 

authority, requiring Defendants, their agent(s) or assign(s), to instruct all search engines to 

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permanently delist or deindex the Subject Domain Name(s) and any other domain names used by 

Defendants, and, if within five (5) days of entry of such order Defendants fail to make such a 

written instruction, the Court order the act to be done by another person appointed by the Court 

at Defendants’ expense, such as the Clerk of Court, pursuant to Federal Rule of Civil Procedure 

70(a). 

g. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, authorizing Plaintiffs to serve the injunction on any e-mail service 

provider with a request that the service provider permanently suspend the e-mail addresses which 

are or have been used by Defendants in connection with Defendants’ promotion, offering for 

sale, and/or sale of goods using counterfeits, and/or infringements of the Plaintiffs’ Marks. 

h. Entry of an order requiring, upon Plaintiffs’ request, Defendants to request 

in writing permanent termination of any messaging services, Seller IDs, usernames, and social 

media accounts they own, operate, or control on any messaging service and social media 

platform. 

i. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

this Court’s inherent authority that, upon Plaintiffs’ request, the applicable governing messaging 

service and Internet marketplace, social media, and image hosting website operators and/or 

administrators for the Seller IDs who are provided with notice of an injunction issued by the 

Court, disable and/or cease facilitating access to the Seller IDs and any other alias e-commerce 

stores, seller identification names, photo albums, user names, and private messaging accounts, 

being used and/or controlled by Defendants to engage in the business of marketing, offering to 

sell, and/or selling goods bearing counterfeits and infringements of the Plaintiffs’ Marks. 

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j. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority that, upon Plaintiffs’ request, any messaging service and Internet 

marketplace, social media, and image hosting website operators and/or administrators, registrar 

and/or top level domain (TLD) Registry for the Seller IDs and Subject Domain Names who are 

provided with notice of an injunction issued by the Court, identify any e-mail address known to 

be associated with Defendants’ respective Seller ID or Subject Domain Name. 

k. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

this Court’s inherent authority that, upon Plaintiffs’ request, any messaging service and Internet 

marketplace, social media, and image hosting website operators and/or administrators who are 

provided with notice of the injunction issued by the Court, permanently remove from the 

multiple platforms, which include, inter alia, a Direct platform, Group platform, Seller Product 

Management platform, Vendor Product Management platform, and Brand Registry platform, any 

and all listings and associated images of goods bearing and/or using counterfeits and/or 

infringements of the Plaintiffs’ Marks via the e-commerce stores and Internet based photo 

albums operating under the Seller IDs, and upon Plaintiffs’ request, any other listings and images 

of goods bearing and/or using counterfeits and/or infringements of the Plaintiffs’ Marks linked to 

the same sellers or linked to any other alias e-commerce stores, seller identification names, photo 

albums, user names, and private messaging accounts being used and/or controlled by Defendants 

to promote, offer for sale and/or sell goods bearing and/or using counterfeits and/or 

infringements of the Plaintiffs’ Marks.

l. Entry of an order pursuant to 15 U.S.C. § 1116, 28 U.S.C. § 1651(a), The 

All Writs Act, Federal Rule of Civil Procedure 65, and this Court’s inherent authority that, upon 

Plaintiffs’ request, Defendants and any Internet marketplace, social media, and image hosting 

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website operators and/or administrators who are provided with notice of an injunction issued by 

the Court, immediately cease fulfillment of and sequester all goods of each Defendant bearing 

one or more of the Plaintiffs’ Marks in its inventory, possession, custody, or control, and 

surrender those goods to Plaintiffs. 

m. Entry of an order requiring Defendants to account to and pay Plaintiffs for 

all profits and damages resulting from Defendants’ trademark counterfeiting and infringing and 

unfairly competitive activities and that the award to Plaintiffs be trebled, as provided for under 

15 U.S.C. § 1117, or that Plaintiffs be awarded statutory damages from each Defendant in the 

amount of two million dollars ($2,000,000.00) per each counterfeit trademark used and product 

type offered for sale or sold, as provided by 15 U.S.C. § 1117(c)(2) of the Lanham Act. 

n. Entry of an award pursuant to 15 U.S.C. § 1117 (a) and (b) of Plaintiffs’ 

costs and reasonable attorneys’ fees and investigative fees associated with bringing this action. 

o. Entry of an order pursuant to 15 U.S.C. § 1116, 28 U.S.C. § 1651(a), The 

All Writs Act, Federal Rule of Civil Procedure 65, and the Court’s inherent authority that, upon 

Plaintiffs’ request, Defendants and any financial institutions, payment processors, banks, escrow 

services, money transmitters, or marketplace platforms, and their related companies and 

affiliates, identify and restrain all funds, up to and including the total amount of judgment, in all 

financial accounts and/or sub-accounts used in connection with the Seller IDs and Subject 

Domain Names or other alias e-commerce stores, social media accounts, photo albums, seller 

identification names, user names, private messaging accounts, domain names and/or websites 

used by Defendants presently or in the future, as well as any other related accounts of the same 

customer(s) and any other accounts which transfer funds into the same financial institution 

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account(s), and remain restrained until such funds are surrendered to Plaintiffs in partial 

satisfaction of the monetary judgment entered herein. 

p. Entry of an award of pre-judgment interest on the judgment amount. 

q. Entry of an Order requiring Defendants to pay the cost necessary to 

correct any erroneous impression the consuming public may have received or derived concerning 

the nature, characteristics, or qualities of Defendants’ products, including without limitation, the 

placement of corrective advertising and providing written notice to the public. 

r. Entry of an order for any further relief as the Court may deem just and 

proper. 

DATED: September 8, 2022. Respectfully submitted, 

 STEPHEN M. GAFFIGAN, P.A. 

 By: Stephen M. Gaffigan

 Stephen M. Gaffigan (Fla. Bar No. 025844) 

 Virgilio Gigante (Fla. Bar No. 082635) 

 Christine Ann Daley (Fla. Bar No. 98482) 

 T. Raquel Wiborg-Rodriguez (Fla. Bar. No. 103372) 

 401 East Las Olas Blvd., Suite 130-453 

 Ft. Lauderdale, Florida 33301 

 Telephone: (954) 767-4819 

 E-mail: Stephen@smgpa.net

 E-mail: Leo@smgpa.net

 E-mail: Christine@smgpa.net 

 E-mail: Raquel@smgpa.net

 Attorneys for Plaintiffs 

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SCHEDULE “A” 

[This page is the subject of Plaintiffs’ Motion to File Under Seal. As such, this page has 

been redacted in accordance with L.R. 5.4(b)(1)] 

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SCHEDULE “B” 

VERSACE’S FEDERALLY REGISTERED TRADEMARKS 

Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

1,875,093 January 24, 

1995 

IC 014: goods of precious metals or coated 

therewith, namely necklaces, earrings, 

bracelets, broches, rings, necktie pins, badges 

of precious metal, medallions, belt buckles of 

precious metal (for clothing), jewelry, precious 

gemstones, watches, clocks, chronometers 

IC 021: kitchen utensils, namely serving 

spoons, basting spoons, cork screws, and 

napkin rings not of precious metal; household 

containers, namely ice buckets, containers for 

food and soap; beverage glassware; porcelain 

dishes in general, earthenware, namely mugs, 

basins, baskets, beverageware, bowls, buckets, 

cakeservers, candle holders, chamber pots, 

commemorative plates, cookware, decorative 

plates, dishes, doorknobs made of porcelain or 

earthenware, figurines made of china, crystal, 

earthenware, glass, porcelain, or terracotta, 

vases 

VERSACE 2,121,984 December 16, 

1997 

IC 018: leather or imitations of leather, 

namely, animal skins and hides, handbags, 

wallets, luggage, attache cases, tote bags, 

briefcases, all-purpose sport bags, travelling 

trunks and carry-on bags, shoulder bags, 

garment bags for travelling, keycases, 

umbrellas. 

IC 025: clothing for men, women and children, 

namely belts, coats, raincoats, waistcoats, 

blouses and pullovers, jackets, trousers, skirts, 

dresses, suits, shirts and chemises, T-shirts, 

sweaters, underwear, socks and stockings, 

gloves, ties, scarves, hats and caps, boots, 

shoes and slippers. 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

VERSACE 2,440,541 April 3, 2001 

IC 024: bath linen, bath mats, bed linen; 

blankets; * unfitted fabric * furniture covers. 

IC 021: household or kitchen utensils and 

containers; dinnerware; beverage ware 

glassware sugar bowls; bottle openers; bowls; 

candle holders not of precious metal; china 

ornaments; soap dispensers; figurines in china, 

crystal, porcelain holders for flowers and 

plants; * flower baskets; plates; pots, soap 

boxes; soap holders; vases; parts and fittings 

for the aforesaid goods. 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

2,980,455 August 2, 2005 

IC 014: Articles made of precious metals and 

alloys of precious metals with or without 

precious stones, namely rings, necklaces, 

bracelets, brooches, earrings, tie clips, cufflinks, diamonds, jewelry cases made of 

precious metal, watches, clocks, chronometers, 

watch cases, costume jewelry. 

IC 018: Leather and imitation of leather sold in 

bulk, handbags, wallets, luggage, attache 

cases, tote bags, briefcases, sport bags, 

traveling trunks, carry-on bags, shoulder bags, 

garment bags for traveling, key cases, 

umbrellas, parasols, walking sticks, whips, 

harnesses, saddlery; leather key chains. 

IC 020: Furniture; mirrors, namely looking 

glasses; picture frames; chairs; cupboards; 

cushions; desks; divans; plastic and wood 

doorknobs; figures of bone, ivory, plaster, 

plastic, wax and wood; plastic and wood 

furniture handles for doors, plastic key chains; 

magazine racks; office furniture; pillows; fitted 

furniture covers. 

IC 021: Household or kitchen utensils and 

containers, namely, dinnerware; beverageware; glassware; sugar bowls; beer mugs; 

bottle openers; bowls; candle holders not of 

precious metal; china ornaments; cookware, 

namely non-electric frying pans; corkscrews; 

soap dispensers; figurines in China, crystal, 

earthenware, glass, porcelain and terracotta; 

holders for flowers and plants; perfume 

atomizers sold empty; plates; pots; soapboxes; 

soap holders; vases; flower baskets; porcelain 

and earthenware doorknobs and furniture 

handles for doors. 

IC 024: Fabric for textile use, fabric of 

imitation animal skins, fabric for boots and 

shoes, bath linen; bed linen; blankets; curtains; 

unfitted furniture covers; handkerchiefs; 

kitchen towels; textile wall hangings. 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

 

IC 025: Clothing for men, women and 

children, namely belts, coats, raincoats, 

waistcoats, blouses and pullovers, jackets, 

trousers, skirts, dresses, suits, shirts and 

chemises, T-shirts, sweaters, underwear, socks 

and stockings, gloves, ties, scarves, hats and 

caps, boots, shoes and slippers. 

IC 027: Carpets, rugs, mats and matting, 

linoleum and other materials for covering 

existing floors; non-textile wall hangings; nontextile wall decorations. 

3,194,501 January 2, 2007 

IC 014: Articles made of precious metals and 

alloys of precious metals, with or without 

precious stones, namely, rings, necklaces, 

bracelets, earrings, tie clips, cuff-links, 

watches, costume jewellery. 

IC 018: Leather and imitation leather goods, 

namely, handbags, wallets, luggage, attaché 

cases, tote bags, briefcases, sport bags, 

traveling trunks, carry-on bags, shoulder bags, 

garment bags for traveling. 

IC 024: Fabric for textile use, fabric for boots 

and shoes, bath linen, bed linen; bed blankets; 

unfitted fabric furniture covers 

IC 025: Clothing for men, women and 

children, namely belts, coats, raincoats, 

waistcoats, blouses and pullovers, jackets, 

trousers, skirts, dresses, suits, shirts and 

chemises, t-shirts, sweaters, underwear, socks 

and stockings, gloves, ties, scarves, hats and 

caps, boots, shoes and slippers 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

3,199,127 January 16, 

2007 

 IC 014: Articles made of precious metals and 

alloys of precious metals, with or without 

precious stones, namely, rings, necklaces, 

bracelets, brooches, earrings, tie clips, cufflinks, watches, watch cases, costume 

jewellery, parts and fittings for all the 

aforesaid goods 

IC 018: Leather and imitation leather goods, 

namely, handbags, wallets, luggage, tote bags, 

briefcases, sport bags, carry-on bags, shoulder 

bags, garment bags for traveling, key cases 

IC 024: Fabric for textile use, fabric of 

imitation animal skins, fabric for boots and 

shoes, bath linen, bed linen; bed blankets; and 

kitchen towels 

3,453,992 June 24, 2008 

 IC 018: Leather and imitation leather goods, 

namely, handbags, wallets, luggage, tote bags, 

key cases 

IC 020: Furniture; mirrors, namely, looking 

glasses; cushions; desks; divans; office 

furniture; pillows; parts and fittings for the 

aforesaid furniture goods, namely, fitted 

furniture covers not of paper 

IC 024: bath linen; bed linen; bed blankets 

IC 025: Clothing for men, women and 

children, namely, belts, coats, waistcoats, 

blouses and pullovers, jackets, trousers, skirts, 

dresses, shirts and chemises, T-shirts, 

underwear, socks and stockings, gloves, ties, 

scarves, hats and caps, shoes and slippers 

VERSACE 4,398,385 September 10, 

2013 

IC 014: Articles made of precious metals and 

alloys of precious metals with or without 

precious stones, namely, rings, necklaces, 

bracelets, earrings, cufflinks, watches 

IC 027: bath mats 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

5,937,934 December 17, 

2019 

IC 009: Protective cases for cell phones; 

Protective cases for laptop computers; 

Protective cases for portable media players. 

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

6,082,409 June 23, 2020 

IC 014: Jewellery, precious stones; horological 

and chronometric instruments; rings being 

jewelry; cuff links; bracelets; watch bands; 

watch cases being parts of watches; clock 

cases being parts of clocks; watch chains; 

jewelry chains; pendants; necklaces; 

chronographs as watches; timepieces; 

stopwatches; chronoscopes; diamonds; tie 

pins; figurines of precious metal; gold thread 

jewelry; wire of precious metal for use in the 

making of jewelry, namely, jewelry cable; 

silver thread jewelry; jewellery; cloisonné 

jewellery; badges of precious metal; clock 

hands; alloys of precious metal; ingots of 

precious metals; movements for clocks and 

watches; medals; lockets; earrings; jewellery 

of yellow amber; ornaments of precious metal 

in the nature of jewelry; ornaments of jet, shoe 

ornaments of precious metal being shoe 

jewelry; hat ornaments of precious metal being 

hat jewelry; pendulum clocks; atomic clocks; 

wristwatches; pocket watches; master clocks; 

electric clocks and watches; jewellery stones; 

key rings; clock dials; boxes of precious metal; 

cases for clock- and watchmaking being parts 

for watches and clocks; jewellery cases; cases 

adapted for holding watches; pins being 

jewelry; ornamental lapel pins; brooches being 

jewelry; statuettes of precious metal; paste 

jewellery; time instruments being 

chronometric instruments; alarm clocks; watch 

crystals 

IC 018: Leather and imitations of leather; 

animal skins, animal hides; women's handbags; 

pocket wallets; luggage; garment carriers 

being garment bags for travel; rucksacks; 

document cases; sports bags; trunks being 

luggage; travelling trunks; carry-on bags; sling 

bags; garment bags for travel; valises; 

suitcases; attaché cases; purses; travelling 

handbags; notecases, namely, business card 

cases; key cases, umbrellas; parasols; beach 

parasols; walking sticks; alpenstocks; whips; 

harness for horses; saddlery

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Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

 

IC 025: Clothing, namely, shirts, pants, jeans, 

sweaters, skirts, dresses; footwear; headwear; 

clothing of imitations of leather, namely, 

pants, jackets; clothing of leather, namely, 

pants, jackets; motorists' clothing, namely, 

motorists' jackets, driving gloves; cyclists' 

clothing, namely, biking shorts, athletic shirts, 

cycling gloves; clothing for gymnastics, 

namely, leotards, leggings; gowns; bath robes; 

bandanas; berets; underclothing; smocks; boas; 

teddies being undergarments; garters; sports 

shoes; stockings; slippers; socks; jodhpurs; 

short-sleeve shirts; shirts; jackets; top hats; 

coats; hoods; belts for clothing; money belts; 

tights; collars; detachable collars; suits; 

beachwear; ties as clothing; ascots; headbands 

for clothing; pocket squares; dress pocket 

squares; skirts; jumper dresses; girdles; gloves; 

arm length gloves; rain coats; ready-to-wear 

clothing, namely, shirts, pants, dresses; 

knitwear, namely, knit shirts, knit skirts, knit 

dresses, knit sweaters, knit jackets; jerseys 

being clothing; leg warmers; leggings; liveries; 

sports jerseys; hosiery; swimsuits; pullovers; 

muffs; maniples; pelerines; mantillas; sleep 

masks; miniskirts; cowls being clothing; boxer 

shorts; bathing drawers as clothing; vests, 

trousers; parkas; pelisses; furs being clothing; 

shirt yokes; pyjamas; wristbands as clothing; 

ponchos; sock suspenders; brassieres; sandals; 

bath sandals; shoes; bath slippers; gymnastic 

shoes; beach shoes; shawls; sashes for wear; 

underpants; wimples; topcoats; outerclothing, 

namely, jackets, coats, vests; petticoats; slips 

being undergarments; shirt fronts; ankle boots; 

boots; fur stoles; t-shirts; combinations being 

clothing; uniforms; veils; visors being 

headwear; wooden shoes 

VERSACE 6,088,586 June 30, 2020 

 IC 009: Protective cases for cell phones; 

Protective cases for laptop computers; 

Protective cases for portable media players. 

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SCHEDULE “C” 

JIMMY CHOO’S FEDERALLY REGISTERED TRADEMARKS 

Trademark Registration 

Number 

Registration 

Date Class(es) / Relevant Goods 

JIMMY CHOO 2,641,408 October 29, 

2002 IC 025: footwear, namely, boots and shoes. 

JIMMY CHOO 3,491,347 August 26, 

2008 

IC 025: Footwear, namely, boots, shoes, 

sandals, slippers, sneakers; headgear, namely, 

hats, scarves, baseball caps 

CHOO 4,934,632 April 12, 2016 

IC 018S: Backpacks made of leather and 

imitations of leather, garment bags for travel 

made of leather or imitations of leather, beach 

bags made of leather or imitations of leather 

and briefcases made of leather or imitations of 

leather; handbags, travelling bags, trunks, 

purses, wallets, clutch bags, travel wallets, 

luggage tags, luggage label holders, cosmetic 

bags sold empty, vanity bags sold empty, 

pouches, namely, drawstring pouches, leather 

pouches, imitation leather pouches, textile 

pouches, attaché cases, cases of leather or 

leather board, bags, namely, all-purpose sports 

bags, weekend bags, tote bags, beach bags, 

evening bags, overnight bags, canvas shopping 

bags, textile shopping bags, leather shopping 

bags, garment bags for travel, leather and 

imitation leather bags, shoe bags for travel, 

leather or imitations of leather cases for keys, 

leather key holders, key cases, key bags, credit 

card cases and debit card cases; business card 

holders in the nature of card cases and wallets, 

credit card holders, business card cases; 

document cases; boxes of leather or leather 

board; hat boxes made of leather or imitations 

of leather; parasols, umbrellas, walking sticks; 

clothing for pets, collars and leads for animals; 

parts and fittings for the aforesaid goods 

IC 025: Clothing, namely, raincoats, hosiery, 

belts, shawls, stoles, swimwear, bikinis and 

kaftans, fur coats, fur collars, fur stoles, 

footwear; headgear, namely, sun hats, caps, 

and swimming hats; scarves; gloves, hats 

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