UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF SOUTH FLORIDA
CASE NO. 09-CIV-22943- LENARD/TURNOFF
CHANEL, INC.,
Plaintiff,
v.
LANGS LEY et al.,
Defendants.
PERMANENT INJUNCTION
THIS MATTER having come before the Court upon Plaintiff, Chanel, Inc.’s (“Chanel” or “Plaintiff”) Motion for Final Default Judgment against Defendant Langs Ley a/k/a Rock Lee a/k/a Thomas Cook a/k/a Timothy Wilson (“Ley”), the Court having granted the Motion does hereby:
ORDER AND ADJUDGE that Ley and his respective officers, agents, servants, employees and attorneys, and all persons in active concert and participation with him are hereby permanently restrained and enjoined from:
(a)manufacturing or causing to be manufactured, importing, advertising, or promoting, distributing, selling or offering to sell counterfeit and infringing goods using the Chanel Marks;
(b)using the Chanel Marks in connection with the sale of any unauthorized goods;
(c)using any logo, and/or layout which may be calculated to falsely advertise the services or products of Ley, replicasi.com, sacmoda.com, semelur.com, qreplicas.com, bagsjewelryshoesnmore.com, seleczions.com, and/or any other website or business, as being sponsored by, authorized by, endorsed by, or in any way associated with Chanel;
(d)falsely representing himself as being connected with Chanel, through sponsorship or association;
(e)engaging in any act which is likely to falsely cause members of the trade and/or of the purchasing public to believe any goods or services of Ley, replicasi.com, sacmoda.com, semelur.com, qreplicas.com, bagsjewelryshoesnmore.com, seleczions.com, and/or any other website or business, are in any way endorsed by, approved by, and/or associated with Chanel;
(f)using any reproduction, counterfeit, copy, or colorable imitation of the Chanel Marks in connection with the publicity, promotion, sale, or advertising of any goods sold by Ley, replicasi.com, sacmoda.com, semelur.com, qreplicas.com, bagsjewelryshoesnmore.com, seleczions.com, and/or any other website or business, including, without limitation, handbags, wallets, sunglasses, hair accessories, key chains, belts, shoes, boots, clothing, watches, and jewelry, including, but not limited to, bracelets, earrings, necklaces, rings;
(g)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 goods by Ley, replicasi.com, sacmoda.com, semelur.com, qreplicas.com, bagsjewelryshoesnmore.com, seleczions.com, and/or any other website or business, as being those of Chanel or in any way endorsed by Chanel;
(h)offering such goods in commerce;
(i)otherwise unfairly competing with Chanel;
(j)secreting, destroying, altering, removing, or otherwise dealing with the unauthorized products or any books or records which contain any information relating to the importing, manufacturing, producing, distributing, circulating, selling, marketing, offering for sale, advertising, promoting, renting or displaying of all unauthorized products which infringe the Chanel Marks; and
(k)effecting assignments or transfers, forming new entities or associations or utilizing any other device for the purpose of circumventing or otherwise avoiding the prohibitions set forth above.
FURTHER ORDER AND ADJUDGE: upon Plaintiff’s request, Defendant, those acting in concert with him, and those with notice of the injunction, including any Internet search engines, Web hosts, domain-name registrars and domain-name registries that are provided with notice of the injunction, shall be and are hereby restrained and enjoined from facilitating access to any or all websites through which Defendant engages in the sale of counterfeit and infringing goods using the Chanel Marks.
DONE AND ORDERED in Miami, Florida, this 30 day of June, 2010.