Yeti Coolers, LLC v. The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A ( 2021 )

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA _ Case No. 21-cv-62008-BLOOM/Valle YETI COOLERS, LLC, : Plaintiff, V. THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, Defendants. ORDER GRANTING PLAINTIFF’S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION THIS CAUSE is before the Court upon Plaintiff's Motion for Preliminary Injunction, ECF No. [7], (“Motion”). The Court has carefully considered the Motion, the record in this case, and the applicable law, and is otherwise fully advised. By the instant Motion, Plaintiff, YETI Coolers, LLC (“Plaintiff”), moves for entry of a preliminary injunction against Defendants,' for alleged violations of the Lanham Act, 15 U.S.C. §§ 1114 and 1125(a). The Court held a hearing by video conference on October 12, 2021, which was attended by counsel for Plaintiff only. During the hearing, Plaintiff directed the Court to evidence supporting the Motion for Preliminary Injunction. None of the Defendants formally responded to the Motion, nor have they made any appearance or filing in this case, either individually or through counsel. Because Plaintiff has satisfied the requirements for the issuance of a preliminary injunction, the Court grants the Motion. ! Defendants are the Individuals, Business Entities, and Unincorporated Associations identified on Schedule “A” hereto (collectively “Defendants”). Case No. 21-cv-62008-BLOOM/Valle 1. FACTUAL BACKGROUND? | Plaintiff, YETI Coolers, LLC, is the registered owner of the following trademarks, which are valid and registered on the Principal: Register of the United States Patent and Trademark Office (the “YETI Marks”): Trademark Registration Registration Date Class(es) / Good(s) Number YETI 3,203,869 | January 30,2007 [IC 021 — Portable coolers TUNDRA 4,083,930 | January 10,2012 JIC 021 - Portable coolers ROADIE 4,083,932 | January 10,2012 |IC 021 — Portable Coolers YETI TANK | 4818317 Septet 22, l1C 021 — Portable Coolers RAMBLER 4,998,897 | July 12,2016 {IC 021 - Jugs 2 The factual background is taken from the Plaintiff's Complaint, ECF No. [1]. Plaintiffs Motion for Preliminary Injunction, ECF No. [7], and supporting evidentiary submissions. Plaintiff filed declarations and exhibits annexed thereto in support of its Motion for Preliminary Injunction. The declarations are available in the docket at the following entries: Declaration of Jeni Zuercher, ECF No. [7-1], Declaration of Stephen M. Gaffigan, ECF No. [7-3], and Declaration of Kathleen Burns, ECF No. [7-7]. HOPPER FLIP] 5.171.380 | March 28, 2017 [Ic 021 — Portable Coolers 2 HOPPER 5,232,872 June 27,2017 |IC 021 — Portable coolers IC 021 - Beverageware; cups; drinking glasses; tumblers for use as drinking vessels; jugs; mugs; temperature-retaining drinking vessels; storage containers for household or domestic use, namely, vacuum RAMBLER 5,233,441 June 27,2017 |container for hot or cold food and drink; beer growlers; insulated food and drink containers; stainless steel tumblers for use as drinking vessels; stainless steel drinking glasses; stainless steel beverageware; drinking straws. YETI HOPPER 5,329,935 | November 7, 2017 {IC 021 — Portable coolers YETI 5,885,556 | October 15, 2019 |IC 016 — Lunch bags HAUL 5,886,316 | October 15,2019 |IC 021 —Non-electric coolers IC 021 — Insulated lunch boxes; lunch boxes; lunch bags not of D AYTRIP 5,893,053 October 22, 2019 |paper; insulated lunch bags not of paper; non-electric portable coolers Case No. 21-cv-62008-BLOOM/Valle 6,153,620 September 15, {IC 021 — Non-electric portable B ACKFLIP 2020 coolers FLIP 6,200,636 | November!?, |1¢ 991 — portable coolers 2020 IC 021 - Buckets; plastic buckets; industrial buckets; utility buckets; ranger buckets; fishing buckets; household containers for food and beverages; containers for Y household or kitchen use; plastic ETI 6,211,352 | December 1, 2020 portable household cargo containers; portable non-electric water coolers; water dispensers; insulated water dispensers; portable beverage dispenser; handles specially adapted for beverageware See Declaration of Jeni Zuercher, ECF No. [7-1] at 4-5; ECF No. [1-2] (containing Certificates of Registrations for the YETI Marks at issue.) The YETI Marks are used in connection with the manufacture and distribution of quality goods in the categories identified above. See Declaration of Jeni Zuercher, ECF No. [7-1] at 4-5. Defendants, by operating commercial Internet websites and a supporting domain under Defendants’ respective domain names identified on Schedule “A” hereto (the “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 YETI Marks. See Declaration of Jeni Zuercher, ECF No. [7-1] at 10-14; Case No. 21-cv-62008-BLOOM/Valle Declaration of Stephen M. Gaffigan, ECF No. [7-3] at 2; Declaration of Kathleen Burns, ECF No. [7-7] at 4. ! Although each Defendant may not copy and infringe each YETI 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 YETI Marks. See Declaration of Zuercher, ECF No. [7-1] at 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 YETI Marks. See Declaration of Zuercher, ECF No. [7-1] at 10, 13-14. Counsel for Plaintiff retained Invisible Inc (“Invisible”), a licensed private investigative firm, to investigate the promotion and sale of counterfeit and infringing versions of YETI branded products by certain Defendants and to obtain the available payment account data for receipt of funds paid to these Defendants for the sale of counterfeit versions of YETI branded products. See Declaration of Jeni Zuercher, ECF No. [7-1] at 12; Declaration of Stephen M. Gaffigan, ECF No. [7-3] at 2; Declaration of Kathleen Burns, ECF No. [7-7] at 3. Invisible accessed the Internet websites operating under the Subject Domain Names for Defendant Numbers 1-25 and placed orders via these Subject Domain Names for the purchase of various products, all bearing and/or using counterfeits and infringements of at least one of YETI’s trademarks at issue in this action and requested each product to be shipped to Invisible’s address in the Southern District of Florida. See Declaration of Kathleen Burns, ECF No. [7-7] at 4 and Comp. Ex. 1 thereto, ECF Nos. [7-8 through 7-9]. Each order was processed entirely online and following the placement of the orders, Invisible received information for finalizing payment? for the various products ordered via PayPal, Inc. (“PayPal”) to Defendants’ respective PayPal 3 Invisible was instructed to not transmit the funds to finalize the sale for the orders for most of the Defendants so as to avoid adding money to Defendants’ coffers. See Declaration of Kathleen Burns, ECF No. [7-7] at 4, n.1. □ Case No. 21-cv-62008-BLOOM/Valle accounts, as identified on Schedule “A” hereto! (See id.) Additionally, Invisible captured the PayPal Merchant Identification Numbers (“Merchant IDs”) identified as part of the source code and account data for these Defendants. At the conclusion of the process, the detailed web pages Invisible captured and downloaded? reflecting the YETI branded products promoted and offered for sale via the Subject Domain Names were sent to YETI’s representative, Jeni Zuercher, for inspection. See Declaration of Stephen M. Gaffigan, ECF No. [7-3] at 2; Declaration of Jeni Zuercher, ECF No. [7-1] at 12. Additionally, YETI accessed the Internet websites operating under Defendant Numbers 1-2, 6-7, 9-10, 16-17, 19-21’s Subject Domain Names and placed an order for the purchase of a product bearing counterfeits of, at least, one of the YETI Marks at issue in this action from each of these Defendants. Each order was processed entirely online and following the placement of the orders, YETI captured the PayPal Merchant IDs and any additional e-mail address identified as part of the source code and account data for these Defendants, as identified on Schedule “A” attached hereto. See Declaration of Jeni Zuercher, ECF No. [7-1] at 11 and Comp. Ex. 1 thereto, ECF No. [7-2]. Further, Plaintiff's counsel accessed each of the commercial Internet websites operating under Defendant Numbers 26-60’s Subject Domain Names and downloaded web pages reflecting the YETI branded products promoted and offered for sale via these Subject Domain Names and provided the same to YETI’s representative, Jeni Zuercher, for inspection. See Declaration of Stephen M. Gaffigan, ECF No. [7-3] at 3. 4 The customer service e-mail addresses identified for certain Defendants are also included in Schedule “A” hereto. See Declaration of Kathleen Burns, ECF No. [7-7] at 4, n.2. > The web pages captured and downloaded by Plaintiff's counsel’s office, Stephen M. Gaffigan, P.A., identifying the customer service e-mail addresses for certain Defendants are included in Comp. Ex. | to the Declaration of Kathleen Burns, ECF No. [7-7] and identified on Schedule “A” hereto. : Case No. 21-cv-62008-BLOOM/Valle Plaintiff's representative conducted a review of the YETI branded goods offered for sale by Defendants via the Subject Domain Names by reviewing the Internet websites operating under the Subject Domain Names or the detailed web page captures thereof, and\or the website to which a certain domain name automatically redirects, and determined the products were not genuine versions of YETI’s goods. See Declaration of Jeni Zuercher, ECF No. [7-1], at 13-14. On September 23, 2021, the Plaintiff filed its Complaint, ECF No. [1], against the Defendants for federal trademark counterfeiting and infringement, false designation of origin, cybersquatting, common law unfair competition, and common law trademark infringement. On September 27, 2021, the Plaintiff filed its Ex Parte Application for Entry of Temporary Restraining Order and Preliminary Injunction, ECF No. [7]. On September 28, 2021, this Court entered an Order Granting Ex Parte Application for Entry of Temporary Restraining Order (the “TRO”), ECF No. [10] and temporarily restrained Defendants from infringing the YETI Marks at issue. The Temporary Restraining Order also directed PayPal, Inc. (“PayPal”), to identify and restrain funds in payment accounts associated with Defendants and to divert those funds to a holding account. Pursuant to the Court’s September 28, 2021 Order, Plaintiff served Defendants with a copy of the Complaint together with copies of the Ex Parte Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, and the Court’s September 28, 2021 Temporary Restraining Order, thereby providing notice and copies of the September 28, 2021 Temporary Restraining Order and Plaintiffs’ Ex Parte Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets via email to each Defendant’s corresponding email/online contact form, or via e-mail to Defendant’s registrar of record, and by posting copies of the Temporary Restraining Order and all other pleadings and documents on file in this action on the website Case No. 21-cv-62008-BLOOM/Valle located at http://servingnotice.com/yr6ain/index.html. Thereafter, Certificates of Service were filed confirming service on each Defendant, ECF Nos. [20], [22], and [23]. Il. LEGAL STANDARD To obtain a preliminary injunction, a party must demonstrate “(1) 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, 403 F.3d 1223, 1225-26 (11th Cir. 2005); see also Levi Strauss & Co. v. Sunrise Int’l. Trading Inc., 51 F. 3d 982, 985 (11th Cir. 1995). Il. ANALYSIS The declarations Plaintiff submitted in support of its Motion for Preliminary Injunction 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, and/or distribution of goods bearing and/or using counterfeits, reproductions, or colorable imitations of the YETI Marks, and that the products Defendants are selling and promoting for sale are copies of Plaintiff's products that bear copies of the YETI Marks. B. Because of the infringement of the YETI Marks, Plaintiff is likely to suffer immediate and irreparable injury if a preliminary injunction is not granted. It clearly appears from the following specific facts, as set forth in Plaintiff's Complaint, Motion for Preliminary Injunction, and accompanying declarations on file, that immediate and irreparable loss, damage, and injury will result to the Plaintiff and to consumers because it is more likely true than not that: : Case No. 21-cv-62008-BLOOM/Valle 1. Defendants own or control commercial Internet websites operating under their Subject Domain Names which advertise, promote, offer for sale, and sell products bearing and/or using counterfeit and infringing trademarks in violation of Plaintiffs rights; and 2. There is good cause to believe that more counterfeit and infringing products bearing and/or using Plaintiffs trademarks will appear in the marketplace; that consumers are likely to be misled, confused, and 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 products as Plaintiff's genuine goods. E. Under 15 U.S.C. § 1117(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 YETI Marks. See Reebok Int’l, Ltd. v. Marnatech Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Prods. Co. v. Fuller Brush Co., 299 F.2d 772, 777 (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 Case No. 21-cv-62008-BLOOM/Valle permanent relief.” Levi Strauss & Co., 51 F.3d at 987 (citing Federal Trade Comm'n v. United States Oil & Gas Corp., 748 F.2d 1431, 1433-34 (11th Cir. 1984)); and 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. IV. CONCLUSION Accordingly, it is ORDERED AND ADJUDGED that Plaintiff's Motion, ECF No. [7], is GRANTED as follows: (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 enjoined and restrained until further Order of this Court: a. From manufacturing, importing, advertising, promoting, offering to sell, selling, distributing, or transferring any products bearing and/or using the YETI Marks, or any confusingly similar trademarks, other than those actually manufactured or distributed by the Plaintiff; and b. From secreting, concealing, destroying, selling off, transferring, or otherwise disposing of: (i) any products, not manufactured or distributed by the Plaintiff, bearing and/or using the YETI 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 YETI 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 YETI 10 Case No. 21-cv-62008-BLOOM/Valle Marks or any confusingly similar trademarks, on or in connection with all Internet websites owned and operated, or controlled by them, including the Internet websites operating under the 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 YETI Marks, or any confusingly similar trademarks within domain name extensions, 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 websites registered, owned, or operated by any Defendant, including the Internet websites operating under the Subject Domain Names; (4) Each Defendant shall not transfer ownership of the 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 Subject Domain Names and shall take all steps necessary to retrieve computer files relating to the use of the Subject Domain Names that may have been deleted before the entry of this Order; (6) Upon Plaintiffs request, the privacy protection service for any of the Subject Domain Names for which the registrant uses such privacy protection service to conceal the registrant’s identity and contact information is ordered to disclose to Plaintiff the true identities and contact information of those registrants; 11 Case No. 21-cv-62008-BLOOM/Valle (7) The domain name registrars for the Subject Domain Names shall immediately, to the extent not already done, assist in changing the registrar of record for the Subject Domain Names to a holding account with a registrar of Plaintiff's choosing (the “New Registrar”), excepting any such domain names which such registrars have been notified in writing by Plaintiff has been or will be dismissed from this action, or as to which Plaintiff has withdrawn its request to immediately transfer such domain names. To the extent the registrars do not assist in changing the registrars of record for the domains under their respective control within one (1) business day of receipt of this Order, the top-level domain (TLD) registries, for the Subject Domain Names, or their administrators, including backend registry operators or administrators, within five (5) business days of receipt of this Order, shall change, or assist in changing, the registrars of record for the Subject Domain Names to a holding account with the New Registrar, excepting any such domain name which such registry has been notified in writing by Plaintiff has been or will be dismissed from this action, or as to which Plaintiff has withdrawn its request to immediately transfer such domain name. Upon the change of the registrars of record for the Subject Domain Names, the New Registrar will maintain access to the Subject Domain Names in trust for the Court during the pendency of this action. Additionally, the New Registrar shall immediately institute a temporary 302 domain name redirection which will automatically redirect any visitor to the Subject Domain Names to the following Uniform Resource Locator (“URL”) http://servingnotice.com/yr6ain/index.html, whereon copies of the Complaint, this Order, and all other documents on file in this action are displayed. Alternatively, the New Registrar may update the Domain Name System (“DNS”) data it maintains for the Subject Domain Names, which link the domain names to the IP addresses where their associated websites are hosted, to NS1.LMEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will 12 ! Case No. 21-cv-62008-BLOOM/Valle cause the domain names to resolve to the website where copies of the Complaint, this Order, and all other documents on file in this action are displayed. After the New Registrar has effected this change, the Subject Domain Names shall be placed on lock status by the New Registrar, preventing the modification or deletion of the domains by the New Registrar or Defendants; (8) Upon receipt of notice of this Order, the Defendants and all financial institutions, payment processors, banks, escrow services, money transmitters, or marketplace platforms, including but not limited to, PayPal, Inc. (“PayPal”), and their related companies and affiliates shall, to the extent not already done, (i) immediately identify and restrain all funds in all financial accounts and/or sub-accounts associated with the Internet websites operating under the Subject Domain Names, PayPal payees, merchant identification numbers, and/or the e-mail addresses identified on Schedule “A” hereto, as well as any other related 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; and (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; (9) Upon receipt of notice of this Order, the 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, PayPal and their related companies and affiliates, shall further, to the extent not already done, provide Plaintiffs counsel with all data that details (i) an accounting of the total funds restrained and identify 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) 13 Case No. 21-cv-62008-BLOOM/Valle which have been restrained. No funds restrained by this Order shall be transferred or surrendered by any financial institution, payment phocessor, bank, escrow service, money transmitter, or marketplace website, including but not limited to, PayPal, 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; (10) This Order shall apply to the Subject Domain Names, associated websites, and any other domain names, websites or financial accounts which are being used by the Defendants for the purpose of counterfeiting the YETI Marks and/or unfairly competing with Plaintiff; (11) 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; (12) As a matter of law, this Order shall no longer apply to any Defendant or associated e-commerce store dismissed from this action, or as to which Plaintiff has withdrawn its request for a preliminary injunction; (13) Pursuant to 15 U.S.C. § 1116(d)(5)(D) and Federal Rule of Civil Procedure 65(c), the 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; (14) 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 financial institutions, payment processors, banks, escrow services, and money transmitters, including but not limited to PayPal, and their related companies and 14 Case No. 21-cv-62008-BLOOM/Valle affiliates shall, to the extent not already done, at Plaintiff's request, provide Plaintiffs counsel with any e-mail address known to be associated with the Defendants’ respective Subject Domain Names; (15) This Order shall remain in effect during the pendency of this action, or until further Order of this Court. DONE AND ORDERED in Chambers at Miami, Florida, on October 12, 2021. BETH BLOOM UNITED STATES DISTRICT JUDGE Copies to: Counsel of Record 15 Case No. 21-cv-62008-BLOOM/Valle SCHEDULE “A” DEFENDANTS BY NUMBER, SUBJECT DOMAIN NAME, MERCHANT ID, FINANCIAL ACCOUNT AND E-MAIL ADDRESS Defendant / Financial Account Information Subject Domain Merchant ID E-mail Address germaynepomona@gmail.com ] etidiscount.store MERVINBAIR | HBKEDPFF3T2A4 customerservice0 1 @yetioutdoors.com william 1994zzw@gmail.com ] etibox.store 4TGXGERQR3008 customerservice0 1@yetioutdoors.com ] MERVINBAIR — | UCLDUMU6TZEF3J customerservice0 1@yetioutdoors.com 1 MERVINBAIR Po customerservice01@yetioutdoors.com 1 MERVINBAIR | HBKEDPFF3T2A4 customerservice0 1@yetioutdoors.com ] MERVINBAIR _ | HBKEDPFF3T2A4 customerservice01@yetioutdoors.com ] MERVINBAIR PF customerservice01@yetioutdoors.com 1 MERVINBAIR || HBKEDPFF3T2A4 customerservice0 1@yetioutdoors.com HBKEDPFF3T2A4 1 etioutdoors.online MERVINBAIR | A48WIYRYO9NTU customerservice0 1@yetioutdoors.com | MERVINBAIR _| HBKEDPFF3T2A4 customerservice0 1@yetioutdoors.com 1 MERVINBAIR _ | HBKEDPFF3T2A4 customerservice0 1 @yetioutdoors.com VPWXYV7U8VPUQ Futeng IIc 9ZMHS844U3DEE Xiaoyue IIc Q85J6JIMK8T8C gbk5319263771@163.com 2 trswme.com Qiliang lle 6KPONFIJP3CL5Q coshamzhfopgf@egmail.com TP4G6RNND7U9S GZTGBS9HLPIWS Maozai llc 3G8ZWE7PK6V88S 2 aajon.com YOUBAI LLC 2A VUGMS9R9K5S coshamzhfopef@gmail.com 54SBLHJG6MC2A Weiban llc CUYSPTZYHL888 2 aomcws.com Wusan llc GW7NQZAJIN2QNQ __| coshamzhfopgf@gmail.com RWS9W8V9X8BPN 2 aozsci.com Yaoding llc 8ZJ7D6PGRRZSE coshamzhfopgf(@gmail.com TP4G6RNND7U9S 2 bsolk.com Maozai Ilc 2AVUGMS9ROKSS coshamzhfopgf@gmail.com RWS9W8V9X8BPN 2 dwbipe.com Yaoding Ilc 8ZJ7D6PGRRZSE coshamzhfopef@gmail.com TWWE3V24GY93L 2 foybe.com Xiyan Ile 2NCRHK48N9YCE coshamzhfopgf@gmail.com TWWF3V24GY93L 2 ifvnf.com Xiyan llc 2NCRHK48N9YCE coshamzhfopgf@gmail.com 16 Case No. 21-cv-62008-BLOOM/Valle Defendant / Financial Account Information an ioe 2 narkbt.com Maozai IIc ' | 2AVUGMS9R9OKSS coshamzhfopgf@gmail.com an [aims | SESE 2 nedpz.com Zhimeng llc _ | 2NCRHK48N9YCE coshamzhfopgf@gmail.com fetnon [SSC 2 nsbake.com Maozai Ilc 2AVUGMS9RYKSS coshamzhfopgf@gmail.com | eae 2 obngo.com Xtyan Ile 2NCRHK48N9YCE coshamzhfopef@gmail.com aman [vata [ne 2 ocaite.com Yaoding IIc 8ZJ7D6PGRRZSE coshamzhfopef@gmail.com imton lens [Se 2 ogpfj.com Weiban llc GW7NQZAJIN2QNO | coshamzhfopgf@gmail.com moe (emer (carers Weiban IIc CUYSPTZYHL888 2 onceut.com Wusan llc GW7NQZAJN2QNO | coshamzhfopgf@gmail.com mon [Sac (Sees 2 otwnuc.com YOUBAI LLC 2AVUGMS9RIK5S coshamzhfopgf@gmail.com Q85J6JIMK8T8C ee ee 2 ouecan.com Zezhi llc 9ZMHS844U3 DEE coshamzhfopgf@gmail.com eooeoe (SR (ee Xiyan Ile RWS9W8V9X8BPN 2 supoie.com Yaoding llc 8ZJ7D6PGRRZSE coshamzhfopgf@egmail.com on [anne [eer 2 toaskz.com Xiyan Ile 8ZJ7D6PGRRZSE coshamzhfopgf@gmail.com ‘coon [oan [Sa 2 ugfav.com Maozai llc 2AVUGMS9RYIKS5S coshamzhfopef@gmail.com [mua [nan [ene 2 weeisu.com Xiyan lic 8ZJ7D6PGRRZSE coshamzhfopef@gmail.com acan——Iomun [aes 2 weumir.com Maozai Ilc 2AVUGMS9R9YKSS coshamzhfopgf@gmail.com [seman [om [RE 2 wusoem.com Weiban llc LP42WLXL6UUTC coshamzhfopgf@gmail.com [mean lama [Se 2 ZXSi.com Xiaoyue Ilc 9ZMHS844U3DEE | coshamzhfopgf@gmail.com man [vamn —LaS 2 ziweps.com Weiban llc LP42WLXL6UUTC coshamzhfopgf@gmail.com rome [Res 2 YOUBAI LLC 2AVUGMS9RIKSS coshamzhfopgf@gmail.com nan [eatg AT 2 zylac.com Songlian Ilc 9ZMHS844U3DEE coshamzhfopef@egmail.com {lt ancaareme Fas Ks SB ee 4EREAZU7CIBIC 2 xwtzt.com Ti 8FU8BHO52G4E4 coshamzhfopgf@gmail.com 17 . Case No. 21-cv-62008-BLOOM/Valle Defendant / | Financial Account Information 2 fnwkq.com Yuji llc YUKQ7USX8VJEN coshamzhfopgf@gmail.com Ab mak SSC Dar.Laval@mail.com 4 lullriaby.com N69532YFNZABU Customerservice@teheh.com 4 moriling.shop N69532YFNZABU Customerservice@teheh.com 4 shevme.com CBVECY4ZNLP94 Customerservice@teheh.com 4 imaginetime.shop PK7HSXQJHUFVC Customerservice@teheh.com 4 live-oak.shop PK7HSXQJHUFVC Customerservice@teheh.com 4 long-view.shop PK7HSXQJHUFVC Customerservice@teheh.com 4 miraclelovely.com PK7HSXQJHUFVC Customerservice@teheh.com 4 snipehappy.com PK7HSXQJHUFVC Customerservice@teheh.com 4 our-love.shop PK7HSXQJHUFVC Customerservice@teheh.com 4 paralovely.com PK7HSXQJHUFVC Customerservice@teheh.com 5 t.jicwo.shop Bonsai CoLTD AHHTDKSBL2VN4 _ | Eatrading@hotmail.com 5 dteqpe.shop OKELYPN4VCPT2 Eatrading@hotmail.com ratean [SRE mas 5 t.hefiw.shop Bonsai CoLTD AHHTDKSBL2VN4 Eatrading@hotmail.com mae et ems 5 t.hywwn.shop Bonsai CoLTD AHHTDKSBL2VN4 Eatrading@hotmail.com jeemdnsop [Beat catth [awmarpxsacavn_| 5 t.smduu.shop Bonsai CoLTD AHHTDKSBL2VN4 Eatrading@hotmail.com 18 Case No. 21-cv-62008-BLOOM/Valle Defendant / Financial Account Information Tonggu Hui Xie Hua Department 5 sywzjb.shop Store | LS9OPSG7PHC6LE Eatrading@hotmail.com Tonggu Hui Xie Hua Department 5 bkjtai.shop Store LS9PSG7PHC6LE Eatrading@hotmail.com Guangzhou Ailey Technology 5 wjrfxo.shop CoLTD 3DBZMG4EAQ9H2 Eatrading@hotmail.com CITXKBMRCLVRG Dusi Ile 9ZMHS844U3 DEE mao95806123c@163.com 6 iwetnz.com Nadi lle 9S87WRI6N34UN geraldeuwagez@gmail.com [muecom [Nagi _| Semisearunpes_| 6 mzucoe.com Nagi llc 9ZMHS844U3 DEE geraldeuwagez@egmail.com 7 mtaesn.com Tianshi Ile VLOXT9IC8CFJQC kaiwenrakayakb@gmail.com EIS Bae aE eer 7 nwhvp.com Su 2AVUGMS9ROKSS kaiwenrakayakb@gmail.com mean lowes ORE 7 rmskv.com Chaoyue Ilc VLOXT9IC8CFJQC kaiwenrakayakb@gmail.com Fak is BS BS 7 losgv.com Feishi llc VTKMUDXUXSJYW | kaiwenrakayakb@gmail.com 8 crush-you.shop CSIG6AGAFGYLN rhinoman1984@yahoo.com 8 dream-lover.shop CS9G6AGAFGYLN rhinoman1984@yahoo.com 8 sincerely-friends.shop CS9G6AGAFGYLN rhinoman 1984@yahoo.com Shanghai Jiangxian Network , Technology Co 9 t.atknyi.shop LTD WTXYQRED7HRBU | ScottftPage@outlook.com emma Jiangxian Network Technology Co WTXYQRED7HRBU | ScottftPage@outlook.com 9 t.rurxhv.shop LTD PPZNY49R26B5N teresafsparzygnat@hotmail.com omosim [tt —_| wrens Jiangxian 9 t.uomkhy.shop Network WTXYQRED7HRBU | ScottftPage@outlook.com 19 . Case No. 21-cv-62008-BLOOM/Valle Defendant / P Merchant ID Financial Account Information Subject Domain ayee erenan E-mail Address Technology Co LTD Shanghai Jiangxian Network Technology Co 9 t.xpivrh.shop LTD WTXYQRED7HRBU | ScottftPage@outlook.com mem AOS LS 10 duogea.com H LTD YEIAZU2ZEX6BQY □□□□□□□□□□□□□□□□□□□□□□□□□□ com 10 qucnc.com LTD FP28DPC6RB6MU sreatsalept004@outlook.com 2 eT Th T HHA we to penne pe adkinsspencer9692 1 8@gmail.com 13 Fi ae Ab US AT creelwnsdkb@gmail.com ROAST 1440736896@qq.com 15 softkudos.com BAALIRA A PVJY6RH8MAFJE musherovroma@gmail.com 16 gonmall.com JNRMNJS4MNGQU __| zhangjunjiepo@126.com quvwd6858yat@163.com shoppingservice689@gmail.com 17 avhonda.com JTG82R82Q04X32 daibudjhgf401@163.com Online Store kq70collinsrenata@gmail.com TANA leonardnegative77893658@gmail.com 18 cconline.top HERNANDEZ FGOAO3VB6XYMU | notifications@ecwid.com ctongstop | prsepamoton | NNTGVSLERUG_ 19 chgong.shop price promotion | Z2NHTGV8LZFWUG _ | watermanjohnsonhbh@gmail.com 20 moon.lay-tw.top Leslie Marks TBSBGXCTGJA4N stevenjeparker@outlook.com 3594 chemin S7TLS5R5SUQKSZ8 Georges N4WG62PKRD7R6 caitlyn miller QFYSHUV9FQ2LW Carly Backen, Q2LFV7Q67NFQA Barry Chappell SR2CASBAM6BB4 Theola Lee KQFK5XFTBJW6A Kayoung Kate GSDXGMXD8CZHJ Yoo 2A6FV37AWK46Y Peter Sampson TBKYZSRY2Z3MU Raneen Mazin YY2K5ZTQUWS5D2_ □ keystesvlim@hotmail.com Mona Lisa XEPCKQP75SQD6 lecheecdm@hotmail.com 21 teti-store.com Belle Leong GXQKW38FWV9MA | stevenjeparker@outlook.com 20 Case No. 21-cv-62008-BLOOM/Valle Defendant / Pavee : Merchant ID Financial Account Information Subject Domain y E-mail Address Nadia Azmi —,_ | SULSMRSYAQ948 Nanthini | | FG4C9CZPGGYRU Soyabalu _ | DHKYTD4CVB9ORE Christina Tan | | RHAXGG7ZTSBNA Suji Sujithra SQKXMQ482NWXE Azza Fatin LW3M3YG6YTNVJ Premalatha 5ZP44HVNN39GY Murugan KMC3T7LSCK6XJ Cherry Viernes | VGJGW32CDFJRN Kagn Khoia ZQVM2WXZP7LKL Brandon chua 7BSBGXC7GJA4N Valerie Taylor Stormy-Stezhko@mail.com d4184820@sina.com 22 hasal.buzz TZX6FAPKH9FSY CONTACT2@TOKJINYU.COM 23 TIANBO LLC QBVJAHY2N3UJ6 anawdanaisha@gmail.com Online Store / otfjpirmsb@hotmail.com 24 walmarrt.shop QUANG PHAM | UJGXE9UXXKU3FN remov03 1679@gmail.com Hubei Zhenying Electronic Technology Co., 25 wingzoi.com Ltd. AWGGC622V84J6 contact@cooluoso.com SportWellDone@gmail.com 28 etishoping.com ADitallmallB@gmail.com ADitallmallB@gmail.com 28 etishopps.com SportWellDone@gmail.com |yeteccoereom | | 19 [yetzootsncom | |yetuccoecom | contact2@tokjinyu.com 32 nayeti.top SUPPORT@SERVICELIVEWORK.C 21 . Case No. 21-cv-62008-BLOOM/Valle Subject Domain E-mail Address 32 nayetisales.site SUPPORT@BAZARGENERAL.COM 32 nayetishopsilo.club SUPPORT@BAZARGENERAL.COM 32 nayetisilo.club SUPPORT@SERVICELIVEWORK.C 32 usyeti.club SUPPORT@BAZARGENERAL.COM 32 usyeti.top SUPPORT@BAZARGENERAL.COM 32 usyeticooler.club SUPPORT@BAZARGENERAL.COM 32 usyeticooler.shop SUPPORT@BAZARGENERAL.COM 32 usyeticooler.website SUPPORT@BAZARGENERAL.COM 32 usyeticoolers.club SUPPORT@BAZARGENERAL.COM 32 usyetisales.site SUPPORT@BAZARGENERAL.COM 32 usyetishop.club SUPPORT@BAZARGENERAL.COM 32 usyetishops.site support@servicelivework.com 32 usyetishops.top SUPPORT@SERVICELIVEWORK.C 32 eticooler.site SUPPORT@BAZARGENERAL.COM 32 eticoolersale.club SUPPORT@BAZARGENERAL.COM 32 eticoolersale.online SUPPORT@BAZARGENERAL.COM 32 eticoolersale.website SUPPORT@BAZARGENERAL.COM 32 eticoolersales.cc SUPPORT@BAZARGENERAL.COM 32 eticoolersales.website SUPPORT@BAZARGENERAL.COM 32 eticoolershop.cc SUPPORT@BAZARGENERAL.COM 22 Case No. 21-cv-62008-BLOOM/Valle Subject Domain E-mail Address 32 eticoolerssales.cc SUPPORT@BAZARGENERAL.COM 32 eticoolerssales.shop support@servicelivework.com 32 eticteeys.cc SUPPORT@BAZARGENERAL.COM 32 etiinsale.cc SUPPORT@BAZARGENERAL.COM 32 etiinstore.cc SUPPORT@BAZARGENERAL.COM 32 etionlinee.cc SUPPORT@BAZARGENERAL.COM 32 etionlinel.cc SUPPORT@BAZARGENERAL.COM 32 etionlinett.cc SUPPORT@BAZARGENERAL.COM 32 etisale.cc SUPPORT@BAZARGENERAL.COM 32 etisalede.cc SUPPORT@BAZARGENERAL.COM 32 etisalelk.cc SUPPORT@BAZARGENERAL.COM 32 etisaler.cc SUPPORT@BAZARGENERAL.COM 32 etisaleus.club SUPPORT@BAZARGENERAL.COM 32 etisaleus. website SUPPORT@BAZARGENERAL.COM 32 etishopti.cc SUPPORT@BAZARGENERAL.COM 32 etishopto.cc SUPPORT@BAZARGENERAL.COM 32 etistorell.cc SUPPORT@BAZARGENERAL.COM 32 etistoretu.cc SUPPORT@BAZARGENERAL.COM 32 etisueusd.cc support@servicelivework.com 32 etitosale.cc SUPPORT@BAZARGENERAL.COM 23 Case No. 21-cv-62008-BLOOM/Valle Defendant / Pavee Merchant ID Financial Account Information Subject Domain y E-mail Address contact2@tokjinyu.com 32 etitravel.top SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiusale.online SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiusale.shop SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiuscooler.cc SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiuscoolers.cc SUPPORT@BAZARGENERAL.COM SUPPORT@BAZARGENERAL.COM 32 etiuscoolers. website contact2@tokjinyu.com contact2@tokjinyu.com 32 etiusonl.site SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiussales.online SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiussales.website SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiussaless.online SUPPORT@BAZARGENERAL.COM contact2@tokjinyu.com 32 etiww.cc SUPPORT@SERVICELIVEWORK.C contact2@tokjinyu.com 32 etiyour.cc SUPPORT@SERVICELIVEWORK.C contact2@tokjinyu.com 32 etiyy.top SUPPORT@SERVICELIVEWORK.C 24 Case No. 21-cv-62008-BLOOM/Valle eral AMGEES 25 Case No. 21-cv-62008-BLOOM/Valle Financial Account Information Subject Domain E-mail Address 32 usylout.top SUPPORT@SERVICELIVEWORK.C 26 © Case No. 21-cv-62008-BLOOM/Valle Financial Account Information Subject Domain E-mail Address 35 fccsumecom | coshamzhfopgf@gmail.com 35 mbtecm fT coshamzhfopgf@gmail.com 36 ‘vimowcom Td kaiwenrakayakb@gmail.com 36 wiwecom kaiwenrakayakb@gmail.com 36 eevnbcom □□ kaiwenrakayakb@gmail.com 36 ‘mzowsecom ff kaiwenrakayakb@gmail.com 27 Case No. 21-cv-62008-BLOOM/Valle Financial Account Information Subject Domain E-mail Address 37 mktbeoom | nadagzhcecz@gmail.com 37 focmticom ssf dT nadagzhecz@gmail.com 37 ikysom nadagzhcez@gmail.com 28 Case No. 21-cv-62008-BLOOM/Valle Financial Account Information Subject Domain E-mail Address 38 wmeacm oP sudworthuaetsda@gmail.com 38 ciimcom sudworthuaetsda@gmail.com 39 ‘tismemnecom Df zyanawdanaisha@gmail.com 40 ‘outdoorsston dt abuse@company.site; help@YETlus.c« 40 outdoorkn.shop help@YETIlus.com 40 ‘outtoormmsmy | ecommerce@YETLus.com 4] ‘auvemm dd Customerservice@teheh.com loose sa fates 45 ‘discos | storeroomester.rp46652@gmail.com |nibemincom so | incruaaeom | | [mts | _loudoanestop loose 29 Case No. 21-cv-62008-BLOOM/Valle Defendant / Pavee Merchant ID Financial Account Information Subject Domain y E-mail Address service008@mjcontactforhelp.com 57 tsun.run service024(@mjcontactforhelp.com [wachijoyaom fwnctecuecm | | 30