Tiffany (NJ) LLC v. The Individuals, Business Entities, and Unincorporated Associations Identified On Schedule A

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 25-cv-24398-BLOOM/Elfenbein
TIFFANY (NJ) LLC,
Plaintiff,
v.
THE INDIVIDUALS, BUSINESS ENTITIES,
AND UNINCORPORATED ASSOCIATIONS
IDENTIFIED ON SCHEDULE “A,”
Defendants.
_________________________________________/
ORDER ON MOTION FOR ENTRY OF DEFAULT FINAL JUDGMENT
THIS CAUSE is before the Court upon Plaintiffs Tiffany (NJ) LLC’s (“Plaintiff”), Motion
for Entry of Default Final Judgment Against Defendants, ECF No. [42] (“Motion”), filed on
November 20, 2025. A Clerk’s Default was entered against Defendants on October 28, 2025, ECF
No. [40], as Defendants failed to appear, answer, or otherwise plead to the Amended Complaint,
ECF No. [16], despite having been served. See ECF No. [32]. The Court has carefully considered
the Motion, the record in this case, the applicable law, and is otherwise fully advised. For the
following reasons, Plaintiff’s Motion is granted.
II. 	INTRODUCTION
Plaintiff sued Defendants for trademark counterfeiting and infringement under § 32 of the
Lanham Act, 15 U.S.C. § 1114; false designation of origin under § 43(a) of the Lanham Act,
15 U.S.C. § 1125(a); common-law unfair competition; and common-law trademark infringement.
The Amended Complaint alleges that Defendants are promoting, advertising, distributing, offering
for sale, and/or selling goods bearing and/or using counterfeits and confusingly similar imitations
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of Plaintiff’s registered trademarks within the Southern District of Florida through various Internet
based e-commerce stores operating under their seller names identified on Schedule “A” attached
to Plaintiff’s Motion for Entry of Default Final Judgment (the “E-commerce Store Names”). See
Motion, ECF No. [42] at 20-21.
Plaintiff further asserts that Defendants’ unlawful activities have caused and will
continue to cause irreparable injury to Plaintiff because Defendants have (1) deprived Plaintiff of
its right to determine the manner in which its trademarks are presented to the public through
merchandising; (2) defrauded the public into thinking Defendants’ goods are goods authorized
by Plaintiff; (3) deceived the public as to Plaintiff’s association with Defendants’ goods and the e-
commerce stores that market and sell the goods; and (4) wrongfully traded and capitalized on
Plaintiff’s reputation and goodwill, as well as the commercial value of Plaintiff’s trademarks.
In its Motion, Plaintiff seeks the entry of default final judgment against Defendants1 in an
action alleging trademark counterfeiting and infringement, false designation of origin, common-
law unfair competition, and common-law trademark infringement. Plaintiff further requests that
the Court (1) enjoin Defendants from producing or selling goods that infringe its trademarks; (2)
cancel, or at Plaintiff’s election, transfer the E-commerce Store Names to Plaintiff; (3) assign all
rights, title, and interest to the E-commerce Store Names to Plaintiff and permanently disable,
delist, or deindex the websites’ uniform resource locators (“URLs”) of the E-commerce Store
Names from all internet search engines; (4) require Defendants to instruct the Registrar for each
E-commerce Store Name to permanently close the registration account(s) in which any E-
commerce Store Name is located; (5) authorize Plaintiff to request any e-mail service provider
permanently suspend the e-mail addresses which are or have been used by Defendants in
1 Defendants are the Individuals, Business Entities, and Unincorporated Associations identified on Schedule
“A” of Plaintiff’s Motion, and Schedule “A” of this Order. See ECF No. [42] at 20-21.
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connection with Defendants’ promotion, offering for sale, and/or sale of goods bearing and/or
using counterfeits and/or infringements of Plaintiff’s trademarks; and (6) award statutory
damages.
Pursuant to Federal Rule of Civil Procedure 55(b)(2), the Court is authorized to enter a
final judgment of default against a party who has failed to plead in response to a complaint. “[A]
defendant’s default does not in itself warrant the court entering a default judgment.” DirecTV,
Inc. v. Huynh, 318 F. Supp. 2d 1122, 1127 (M.D. Ala. 2004) (quoting Nishimatsu Constr. Co., Ltd.
v. Houston Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975)). Granting a motion for default
judgment is within the trial court’s discretion. Nishimatsu, 515 F.2d at 1206. Because the
defendant is not held to admit facts that are not well pleaded or to admit conclusions of law, the
court must first determine whether there is a sufficient basis in the pleading for the judgment to
be entered. See id.; see also Buchanan v. Bowman, 820 F.2d 359, 361 (11th Cir. 1987) (“[L]iability
is well-pled in the complaint, and is therefore established by the entry of default . . . .”). Upon a
review of Plaintiff’s submissions, it appears there is a sufficient basis in the pleading for the default
judgment to be entered in favor of Plaintiff.
II. 	FACTUAL BACKGROUND 2
Plaintiff is the owner of the following trademarks (the “Tiffany Marks”), which are valid and
registered on the Principal Register of the United States Patent and Trademark Office (USPTO):
Trademark Registration
Number
Registration
Date Class / Goods
0,023,572 September 5,
1893
IC 6, 14 – Bronzes, Silver and Plated
Ware, and Ornamental Articles in Metal
2 The factual background is taken from Plaintiff’s Amended Complaint, ECF No. [16], Plaintiff’s Motion
for Entry of Default Final Judgment Against Defendants, ECF No. [42], and supporting evidentiary
submissions.
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0,023,573 September 5,
1893 IC 14 – Jewelry and Watches.
TIFFANY 	0,133,063 	July 6, 1920
IC 14 – Jewelry for Personal Wear, Not
Including Watches; and Flat and Hollow
Ware Made of or Plated with Precious
Metal.
TIFFANY & CO. 	1,228,189 February 22,
1983
IC 14 – Decorative Art Objects Made in
Whole or in Part of Precious or Semi-
Precious 	Metals-Namely, 	Figurines,
Boxes, 	Bowls, 	Trays, 	Jewelry, 	Metal
Wares Made in Whole or in Part of
Precious 	or 	Semi-Precious 	Metals-
Namely, 	Business 	Card 	Cases,
Candelabras, 	Candlesticks, 	Cigar 	and
Cigarette 	Boxes, 	Napkin 	Rings, 	and
Bookmarks, 	Semi-Precious 	Stones,
Natural and Cultured Pearls.
TIFFANY 	1,228,409 February 22,
1983
IC 14 – Decorative Art Objects Made in
Whole or in Part of Precious or Semi-
Precious 	Metals-Namely, 	Figurines,
Boxes, 	Bowls, 	Trays, 	Jewelry, 	Semi-
Precious 	Stones, 	and 	Natural 	and
Cultured Pearls.
T & CO. 	1,669,365 December 24,
1991
IC 14 – All Types of Jewelry Made of, or
in Part of, Precious Metals and/or with
Precious or Semi-Precious Stones.
2,359,351 	June 20, 2000
IC 14 – Jewelry; watches and clocks;
decorative art objects made in whole or in
part of precious metals and their alloys,
namely, figurines, boxes.
IC 21 – Decorative boxes, boxes.
5,176,498 	April 4, 2017 	IC 14 – Jewelry
See Decl. of Annabelle Greseth (Greseth Decl.), ECF No. [9-1] ¶ 4; ECF No. [16-1] (containing
Certificates of Registrations for the Tiffany Marks at issue). The Tiffany Marks are used in
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connection with the manufacture, promotion, distribution, and sale of high-quality goods in the
categories identified above. See Greseth Decl., ECF No. [9-1] ¶¶ 4-5.
Defendants, by operating the Internet based e-commerce stores under the seller names (the
“E-commerce Store Names”) identified on Schedule “A” 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 Tiffany Marks. See id. ¶¶ 9-12;
Decl. of Stephen M. Gaffigan (Gaffigan Decl.), ECF No. [9-3] ¶¶ 2-3.
Although each Defendant may not copy and infringe each Tiffany 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 Tiffany Marks. See Greseth Decl., ECF No. [9-1] ¶¶ 9-12;
ECF No. [9-2]. Defendants are not now, nor have they ever been, authorized or licensed to use,
reproduce, or make counterfeits, reproductions, or colorable imitations of the Tiffany Marks. See
Greseth Decl., ECF No. [9-1] ¶¶ 9-10, 12. Plaintiff’s representative reviewed and visually inspected
the various items bearing and/or using the Tiffany Marks offered for sale by Defendants via the
Internet based e-commerce stores operating under the E-commerce Store Names and determined the
products were non-genuine, unauthorized versions of Plaintiff’s goods. See Greseth Decl., ECF No.
[9-1] ¶¶ 10-12; ECF No. [9-2].
III. DISCUSSION
A. Claims
1. 	Trademark Counterfeiting and Infringement Under 15 U.S.C. § 1114 (Count I)
Section 32 of the Lanham Act, 15 U.S.C. § 1114, provides liability for trademark
infringement if, without the consent of the registrant, a defendant uses “in commerce any
reproduction, counterfeit, copy, or colorable imitation of a registered mark in connection with the
sale, offering for sale, distribution, or advertising of any goods or services on or in connection with
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which such use is likely to cause confusion, or to cause mistake, or to deceive.” 15 U.S.C. §
1114(1)(a). In order to prevail on its trademark infringement claim under Section 32 of the Lanham
Act, Plaintiff must demonstrate that (1) it had prior rights to the mark at issue; and (2) Defendants
adopted a mark or name that was the same, or confusingly similar to Plaintiff’s trademark, such
that consumers were likely to confuse the two. Planetary Motion, Inc. v. Techsplosion, Inc., 261
F.3d 1188, 1193 (11th Cir. 2001) (citing Lone Star Steakhouse & Saloon, Inc. v. Longhorn
Steaks, Inc., 106 F.3d 355, 360 (11th Cir. 1997)).
2. 	False Designation of Origin Under 15 U.S.C. § 1125(a) (Count II)
To prevail on a claim for false designation of origin under Section 43(a) of the Lanham
Act, 15 U.S.C. § 1125(a), Plaintiff must prove that Defendants used in commerce, in connection
with any goods or services, any word, term, name, symbol or device, or any combination thereof,
or any false designation of origin that is likely to deceive as to the affiliation, connection, or
association of Defendants with Plaintiff, or as to the origin, sponsorship, or approval, of
Defendants’ goods by Plaintiff. See 15 U.S.C. § 1125(a)(1). The test for liability for false
designation of origin under 15 U.S.C. § 1125(a) is the same as for a trademark counterfeiting and
infringement claim – i.e., whether the public is likely to be deceived or confused by the similarity
of the marks at issue. See Two Pesos, Inc. v. Taco Cabana, Inc., 505 U.S. 763, 780 (1992).
3. 	Common Law Unfair Competition and Trademark Infringement (Counts III and IV)
Whether a defendant’s use of a plaintiff’s trademarks created a likelihood of confusion
between the plaintiff’s and the defendant’s products is also the determining factor in the analysis
of unfair competition under Florida common law. Rolex Watch U.S.A., Inc. v. Forrester, No.
83-cv-8381, 1986 WL 15668, at *3 (S.D. Fla. Dec. 9, 1986) (“The appropriate test for determining
whether there is a likelihood of confusion, and thus trademark infringement, false designation
of 	origin, 	and unfair competition under the common law of Florida, is set forth in John H.
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Harland, Inc. v. Clarke Checks, Inc., 711 F.2d 966, 972 (11th Cir. 1983).”); see also Boston
Prof’l Hockey Ass’n, Inc. v. Dallas Cap & Emblem Mfg., Inc., 510 F.2d 1004, 1010 (5th Cir. 1975)
(“As a general rule . . . the same facts which would support an action for trademark infringement
would also support an action for unfair competition.”).
The analysis of liability for Florida common law trademark infringement is the same as the
analysis of liability for trademark infringement under § 32(a) of the Lanham Act. See PetMed
Express, Inc. v. MedPets.com, Inc., 336 F. Supp. 2d 1213, 1217-18 (S.D. Fla. 2004).
B. Liability
The well-pled factual allegations of Plaintiff’s Amended Complaint properly allege the
elements for each of the claims described above. See Amended Complaint ECF No. [16].
Moreover, the factual allegations in Plaintiff’s Amended Complaint have been substantiated by
sworn declarations and other evidence and establish Defendants’ liability under each of the claims
asserted in the Amended Complaint. Accordingly, default judgment pursuant to Federal Rule of
Civil Procedure 55 is appropriate.
C. Injunctive Relief
Pursuant to the Lanham Act, a district court is authorized to issue an injunction “according
to the principles of equity and upon such terms as the court may deem reasonable,” to prevent
violations of trademark law. See 15 U.S.C. § 1116(a). Indeed, “[i]njunctive relief is the remedy of
choice for trademark and unfair competition cases, since there is no adequate remedy at law for the
injury caused by a defendant’s continuing infringement.” Burger King Corp. v. Agad, 911 F. Supp.
1499, 1509–10 (S.D. Fla. 1995) (citing Century 21 Real Estate Corp. v. Sandlin, 846 F.2d 1175,
1180 (9th Cir. 1988)). Moreover, even in a default judgment setting, injunctive relief is available.
See, e.g., PetMed Express, 336 F. Supp. 2d at 1222–23. Defendants’ failure to respond or otherwise
appear in this action makes it difficult for Plaintiff to prevent further infringement absent an
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injunction. See Jackson v. Sturkie, 255 F. Supp. 2d 1096, 1103 (N.D. Cal. 2003) (“[D]efendant’s
lack of participation in this litigation has given the court no assurance that defendant’s infringing
activity will cease. Therefore, plaintiff is entitled to permanent injunctive relief.”)
Permanent injunctive relief is appropriate where a plaintiff demonstrates that (1) it has
suffered irreparable injury; (2) there is no adequate remedy at law; (3) the balance of hardship
favors an equitable remedy; and (4) an issuance of an injunction is in the public’s interest. eBay,
Inc. v. MercExchange, LLC, 547 U.S. 388, 392–93 (2006). Plaintiff has carried its burden on
each of the four factors. Accordingly, permanent injunctive relief is appropriate.
Specifically, in trademark cases, “a sufficiently strong showing of likelihood of confusion
. . . may by itself constitute a showing of . . . [a] substantial threat of irreparable harm.”
McDonald’s Corp. v. Robertson, 147 F.3d 1301, 1310 (11th Cir. 1998) (second and third alteration
in original); see also Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 986 (11th Cir.
1995) (“There is no doubt that the continued sale of thousands of pairs of counterfeit jeans would
damage LS & CO’s business reputation and decrease its legitimate sales.”). Plaintiff’s Amended
Complaint alleges that Defendants’ unlawful actions have caused Plaintiff irreparable injury and
will continue to do so if Defendants are not permanently enjoined. See Amended Complaint, ECF
No. [16]. Further, the Amended Complaint alleges, and the submissions by Plaintiff show, that the
goods promoted, advertised, offered for sale, and/or sold by Defendants are nearly identical to
Plaintiff’s genuine products and that consumers viewing Defendants’ counterfeit goods post-sale
would actually confuse them for Plaintiff’s genuine products. See id. “Defendants’ actions are
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-
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commerce stores are genuine goods originating from, associated with, and/or approved by
Tiffany.” See Amended Complaint, ECF No. [16] ¶ 25.
Plaintiff has no adequate remedy at law so long as Defendants continue to operate the
E-commerce Store Names because Plaintiff cannot control the quality of what appears to be its
products in the marketplace. An award of monetary damages alone will not cure the injury to
Plaintiff’s reputation and goodwill that will result if Defendants’ infringing and counterfeiting
actions are allowed to continue. Moreover, Plaintiff faces hardship from loss of sales and its
inability to control its reputation in the marketplace. By contrast, Defendants face no hardship if
they are prohibited from the infringement of Plaintiff’s trademarks, which is an illegal act.
Finally, the public interest supports the issuance of a permanent injunction against
Defendants to prevent consumers from being misled by Defendants’ products. See Chanel, Inc. v.
besumart.com, 240 F. Supp. 3d 1283, 1291 (S.D. Fla. 2016) (“[A]n injunction to enjoin infringing
behavior serves the public interest in protecting consumers from such behavior.”). The Court’s broad
equity powers allow it to fashion injunctive relief necessary to stop Defendants’ infringing activities.
See, e.g., Swann v. Charlotte-Mecklenburg Bd. of Educ., 402 U.S. 1, 15 (1971) (“Once a right and a
violation have been shown, the scope of a district court’s equitable powers to remedy past wrongs is
broad, for . . . [t]he essence of equity jurisdiction has been the power of the Chancellor to do equity
and to mould each decree to the necessities of the particular case.” (citation and internal quotation
marks omitted)); United States v. Bausch & Lomb Optical Co., 321 U.S. 707, 724 (1944) (“Equity
has power to eradicate the evils of a condemned scheme by prohibition of the use of admittedly valid
parts of an invalid whole.”).
Defendants have created an Internet-based counterfeiting scheme in which they are
profiting from their deliberate misappropriation of Plaintiff’s rights. Accordingly, the Court may
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fashion injunctive relief to eliminate the means by which Defendants are conducting their
unlawful activities by canceling or transferring the E-commerce Store Names and assigning all
rights, title, and interest to the E-commerce Store Names to Plaintiff, permanently closing the
registration accounts in which the E-commerce Store Names are located, instructing all search
engines to permanently disable, delist, or de-index the websites’ uniform resource locators
(“URLs”) and E-commerce Store Names, and permanently suspending the e-mail addresses,
which are or have been used by Defendants, such that these means may no longer be used as
instrumentalities to further the sale of counterfeit goods.
D. Statutory Damages for the Use of Counterfeit Marks
In a case involving the use of counterfeit marks in connection with a sale, offering for sale,
or distribution of goods, 15 U.S.C. § 1117(c) provides that a plaintiff may elect an award of
statutory damages at any time before final judgment is rendered in the sum of not less than $1,000
nor more than $200,000 per counterfeit mark per type of good. 15 U.S.C. § 1117(c)(1). In addition,
if the Court finds that Defendants’ counterfeiting actions were willful, it may impose damages
above the maximum limit up to $2,000,000 per mark per type of good. 15 U.S.C. § 1117(c)(2).
Pursuant to 15 U.S.C. § 1117(c), Plaintiff has elected to recover an award of statutory damages as
to Count I of the Amended Complaint.
The Court has wide discretion to determine the amount of statutory damages. See PetMed
Express, 336 F. Supp. 2d at 1219 (citing Cable/Home Commc’n Corp. v. Network Prod., Inc., 902
F.2d 829, 852 (11th Cir. 1990)). An award of statutory damages is appropriate despite a plaintiff’s
inability to prove actual damages caused by a defendant’s infringement. Under Armour, Inc. v.
51nfljersey.com, No. 13-62809-CIV, 2014 WL 1652044, at *7 (S.D. Fla. Apr. 23, 2014) (quoting
Ford Motor Co. v. Cross, 441 F. Supp. 2d 837, 852 (E.D. Mich. 2006) (“[A] successful plaintiff
in a trademark infringement case is entitled to recover enhanced statutory damages even where its
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actual damages are nominal or non-existent.”)); Playboy Enter., Inc. v. Universal Tel-A-Talk, Inc.,
No. CIV.A. 96-6961, 1998 WL 767440, at *8 (E.D. Pa. Nov. 3, 1998) (awarding statutory damages
where plaintiff failed to prove actual damages or profits). Indeed, Congress enacted a statutory
damages remedy in trademark counterfeiting cases because evidence of a defendant’s profits in
such cases is almost impossible to ascertain. See S. REP. NO. 104-177, pt. V(7) (1995) (discussing
purposes of Lanham Act statutory damages); see also PetMed Express, 336 F. Supp. 2d at 1220
(statutory damages are “[e]specially appropriate in default judgment cases due to infringer
nondisclosure”). This case is no exception.
This Court may award statutory damages “without holding an evidentiary hearing based
upon affidavits and other documentary evidence if the facts are not disputed.” Perry Ellis Int’l,
Inc. v. URI Corp., No. 06-cv-22020, 2007 WL 3047143, at *1 (S.D. Fla. Oct. 18, 2007). Although
the Court is permitted to conduct a hearing on a default judgment regarding damages pursuant to
Fed. R. Civ. P. 55(b)(2)(B), an evidentiary hearing is not necessary where there is sufficient
evidence on the record to support the request for damages. See SEC v. Smyth, 420 F.3d 1225, 1232
n.13 (11th Cir. 2005) (“Rule 55(b)(2) speaks of evidentiary hearings in a permissive tone . . . We
have held that no such hearing is required where all essential evidence is already of record.”)
(citations omitted); see also PetMed Express, 336 F. Supp. 2d at 1223 (entering default judgment,
permanent injunction and statutory damages in a Lanham Act case without a hearing).
Here, the allegations in the Amended Complaint, which are taken as true, clearly establish
Defendants intentionally copied Tiffany Marks for the purpose of deriving the benefit of Plaintiff’s
famous reputation. As such, the Lanham Act permits the Court to award up to $2,000,000 per
infringing mark on each type of good as statutory damages to ensure that Defendants do not
continue their intentional and willful counterfeiting activities.
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The evidence in this case demonstrates each Defendant promoted, distributed, advertised,
offered for sale, and/or sold at least one (1) type of good bearing and/or using at least one (1) mark
which is in fact a counterfeit of the Tiffany Marks. See Amended Complaint, ECF No. [16], ¶¶ 15,
24-25, 40; Greseth Decl., ECF No. [9-1] ¶¶ 9-12; Gaffigan Decl., ECF No. [9-3] ¶ 2 and Comp.
Ex. 1 thereto, ECF Nos. [9-4] – [9-6]; Greseth Decl. in Support of Motion, ECF No. [42-1] ¶ 5.
Based on the above considerations, Plaintiff suggests the Court award statutory damages by
starting with a baseline of twenty thousand dollars ($20,000.00), trebled to reflect Defendants’
willfulness, and doubled for the purpose of deterrence, resulting in one hundred twenty thousand
dollars ($120,000.00) per trademark counterfeited per type of good offered for sale and/or sold per
Defendant. See Greseth Decl. in Support of Motion, ECF No. [42-1] ¶¶ 5-6 and Ex. 1 thereto, ECF
No. [42-2]. The award should be sufficient to deter Defendants and others from continuing to
counterfeit 	or 	otherwise infringe Plaintiff’s trademarks, compensate Plaintiff, and punish
Defendants, all stated goals of 15 U.S.C. § 1117(c). The Court finds that this award of statutory
damages falls within the permissible statutory range under 15 U.S.C. § 1117(c) and is just.
E. Damages for False Designation of Origin
Plaintiff’s Amended Complaint also sets forth a cause of action for false designation of
origin pursuant to § 43(a) of the Lanham Act (Count II). See 15 U.S.C. § 1125(a). As to Count II,
the allowed scope of monetary damages is also encompassed in 15 U.S.C. § 1117(c). Accordingly,
judgment on Count II is limited to the amount awarded pursuant to Count I and entry of the
requested equitable relief.
F. 	Damages for Common Law Unfair Competition and Trademark Infringement
Plaintiff’s Amended Complaint further sets forth a cause of action under Florida’s common
law of unfair competition (Count III) and trademark infringement (Count IV). Judgment on
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Count III and Count IV are also limited to the amount awarded pursuant to Count I and entry of
the requested equitable relief.
IV. CONCLUSION
Accordingly, it is ORDERED AND ADJUDGED that Plaintiff’s Motion, ECF No. [42],
is 	GRANTED 	against those Defendants listed in the attached Schedule “A.” Default Final
Judgment will be entered by separate order. The Clerk shall CLOSE the case.
DONE AND ORDERED in Chambers at Miami, Florida, on December 10, 2025.
_____ ___ _______________________
BETH BLOOM
UNITED STATES DISTRICT JUDGE
Copies to:
Counsel of Record
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SCHEDULE “A”
DEFENDANTS BY NUMBER, E-COMMERCE STORE NAME,
AND E-MAIL ADDRESS
Def.
No.
Defendant /
E-commerce Store Name E-Mail Address
1 	121brand.com 	brandshopua121@gmail.com
2 	2025newsale.ru
3 	88bag.ru porto@portotheme.com
Gary88bag@163.com
4 	bagloveclub.life
5 	besttagsov.click 	sale@mamilike.top
5 	goodtiesvs.click 	sale@mamilike.top
5 	townlikevs.click 	sale@mamilike.top
5 	yilikear.click 	sale@mamilike.top
6 	cchenjewellery.com
cchenjewellery@gmail.com
pw-
e7825643cb65e52473851f3a705ef59b@privacyguardian.o
rg
7 	coraljewelers.com
coralperfect@gmail.com
pw-
29d4a4cfb99a1403778943de6d798bc7@privacyguardian.o
rg
8 	daikunjewels.com
Daikunjewelry@gmail.com
pw-
1a3e39d46092685dae9fa41509a9ddf5@privacyguardian.or
g
9 	drjewellery.to 	jewellery.to@gmail.com
10 	elovidy.store 	info@elovidy.store
11 	hypeunique.org
cshypeunique@gmail.com
support@hypeunique.is
ad20c054c5b640d89a96b48735784fec.protect@withheldfo
rprivacy.com
12 	jewelrybyvessa.com 	info@myvessa.com
12 	jewellerybyvessa.com myvessaco@gmail.com
info@myvessa.com
13 	modkicks.ru 	modkicks.ru@gmail.com
14 	onlinechics.com 	info@onlinechics.com
15 	primereplica.com f834fdc761464bafbcd0c088b06f9665.protect@withheldfor
privacy.com
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16 	purseglow.us
support@purseglow.us
elashianzel@hotmail.com
MAITHANHECONOMIC53@GMAIL.COM
17 	relaxbuyer.com
contacts@relaxbuyer.com
godisone9559@gmail.com
Hello@relaxbuyer.com
18 	ssjoyas.com 	sales@relojesmore.com
19 	stbag.com
pwp-
c31ddc2bd23ebdfb333f389501ea63da@privacyguardian.or
g
20 	tidelocker.shop 	support@tidelocker.shop
21 	vogolux.com 	info@vogolux.com
22 	wowjewelry.cn xbenbenaaa@gmail.com
SERVICEVIP8@OUTLOOK.COM
Case 1:25-cv-24398-BB Document 43 Entered on FLSD Docket 12/11/2025 Page 15 of 15