gucci v. galaxy handbags.com

7/30/2019 Gucci v. Galaxy Handbags.com

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

GUCCI AMERICA, INC., a New York

corporation,

Plaintiff,

vs.

THE PARTNERSHIP or UNINCORPORATED

ASSOCIATION doing business as

GALAXYAYHANDBAGS.COM, and DOES1-1000,

Defendants. /

COMPLAINT FOR INJUNCTIVE RELIEF

Plaintiff, Gucci America, Inc., (Plaintiff or Gucci) hereby sues Defendants, the

Partnership or Unincorporated Association doing business as galaxyayhandbags.com and Does

1-1000 (collectively Defendants). Defendants are promoting, selling, offering for sale and

distributing goods bearing counterfeits and confusingly similar imitations of Plaintiffs

trademarks within this judicial district through various fully interactive Internet websites

operating under, at least, the domain names identified on Schedule A hereto (the Subject

Domain Names). In support of its claims, Plaintiff alleges as follows:

JURISDICTION AND VENUE

1. This is an action for federal trademark infringement, counterfeiting, falsedesignation of origin, cybersquatting, common law unfair competition, and common law civil

conspiracy pursuant to 15 U.S.C. 1114, 1116, 1121, 1125(a), and 1125(d), and The All Writs

Act, 28 U.S.C. 1651(a). Accordingly, this Court has subject matter jurisdiction under 15 U.S.C.

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

!ase 1:12-cv-23997-UU Document 1 Entered on FLSD Docket 11/03/2012 Page 1 of 25


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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 judicial district because theydirect business activities toward and conduct business with consumers within the State of Florida

and this judicial district through at least the fully interactive Internet websites operating under the

Subject Domain Names.

3. Venue is proper in this Court pursuant to 28 U.S.C. 1391 since Defendants are,upon information and belief, aliens who engage in infringing activities and cause harm within

this judicial district. Defendants have also advertised and upon information and belief, have

made sales and shipped infringing products into this judicial district.

THE PLAINTIFF

4. Gucci is a corporation organized under the laws of the State of New York with itsprincipal place of business located at 685 Fifth Avenue, New York, New York 10022. Gucci

operates boutiques throughout the world, including within this Judicial District. Gucci is, in part,

engaged in the business of manufacturing and distributing throughout the world, including within

this Judicial District, a variety of high quality luxury goods, including, but not limited to,

handbags, wallets, shoulder bags, duffel bags, cosmetic cases, shoes, belts, sunglasses, watches,

jewelry, and hats, under multiple world famous common law and Federally registered

trademarks, including those identified in Paragraph 17 below. Gucci offers for sale and sells its

trademarked goods within this Judicial District. Defendants sales of counterfeit and infringing

Gucci branded products are causing damage to Gucci within this jurisdiction. Gucci regularly

enforces its intellectual property rights and authorized that this action be brought in its name.



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5. Like many other famous trademark owners, Gucci suffers ongoing daily andsustained violations of its trademark rights at the hands of counterfeiters and infringers, such as

Defendants herein, who wrongfully reproduce and counterfeit Guccis trademarks for the twin

purposes of (i) duping and confusing the consuming public and (ii) earning substantial profits.

6. In order to combat the indivisible harm caused by the combined actions ofDefendants and others engaging in similar conduct, each year Gucci expends significant amounts

of money in connection with trademark enforcement efforts, including legal fees, investigative

fees, and support mechanisms for law enforcement, such as field training guides and seminars.

The recent explosion of counterfeiting over the Internet has created an environment which

requires companies, such as Gucci, to file a large number of lawsuits, often it later turns out,

against the same individuals and groups in order to protect both consumers and itself from the ill

effects of confusion and the erosion of the goodwill connected to the Gucci brand. The financial

burden on Gucci and companies similarly situated is staggering, as is the resulting burden on the

Federal court system.

THE DEFENDANTS

7. Defendants are partnerships and unincorporated business associations whichoperate through domain names registered with registrars in multiple countries and are comprised

of individuals and/or business entities of unknown makeup, all of whom, upon information and

belief, reside in the Peoples Republic of China or other foreign jurisdictions with lax trademark

enforcement systems. Defendants have the capacity to be sued pursuant to Federal Rule of Civil

Procedure 17(b). Defendants conduct pervasive business throughout the United States, including

within this judicial district through the operation of fully interactive commercial websites



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existing under the Subject Domain Names. The domain names names used by Defendants are

set forth on Schedule A hereto.

8. Upon information and belief, Defendant galaxyayhandbags.com uses the aliasesidentified on Schedule A hereto in conjunction with the operation of its business.

9. Gucci is presently unaware of the true names of Does 1-1,000, although they aregenerally identified as the owners, operators, partners, managing agents and/or co-conspirators of

Defendant partnerships or unincorporated associations operating under the Subject Domain

Names. Gucci will amend this Complaint upon discovery of the identities of such fictitious

Defendants.

10. Defendants are part of an ongoing conspiracy to create and maintain an illegalmarketplace enterprise on the World Wide Web, the purposes of which are to (i) confuse

consumers regarding the source of the Defendants goods for profit, and (ii) expand the

marketplace for illegal, counterfeit Gucci branded goods while shrinking the legitimate

marketplace for genuine Gucci goods. The natural and intended byproduct of Defendants

actions is the erosion and destruction of the overall marketplace in which Gucci operates and the

goodwill associated with Guccis famous name and associated trademarks.

11. Defendants are the past and present moving and conscious forces behind theoperation of the commercial Internet websites operating under the Subject Domain Names.

12. Upon information and belief, Defendants directly engage in unfair competitionwith Gucci by (i) offering for sale and selling goods bearing counterfeits and infringements of

Guccis trademarks to consumers within the United States and this judicial district through

multiple fully interactive commercial websites operating under the Subject Domain Names and

additional domain names not yet known to Gucci and (ii) creating and maintaining an illegal



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marketplace enterprise for the purpose of diverting business from Guccis legitimate marketplace

for its genuine goods. 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 shipment of counterfeit branded goods into the State, and by operating an illegal marketplace

enterprise which impacts and interferes with commerce throughout the United States, including

within the State of Florida.

13. Defendants have registered, established or purchased, and maintained the SubjectDomain Names. Upon information and belief, Defendants have engaged in fraudulent conduct

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

misleading information to their various Registrars during the Registration or maintenance

process. Upon information and belief, Defendants have anonymously registered and maintained

some of the Subject Domain Names for the sole purpose of engaging in illegal counterfeiting

activities.

14. Upon information and belief, Defendants will continue to register or acquire newdomain names for the purpose of selling and/or offering for sale goods bearing counterfeit and

confusingly similar imitations of Guccis trademarks unless preliminarily and permanently

enjoined. Moreover, upon information and belief, Defendants and their coconspirators will

continue to maintain and grow their illegal marketplace enterprise at Guccis expense unless

preliminarily and permanently enjoined.

15. Defendants entire Internet-based website businesses and associated marketplaceamount to nothing more than illegal operations established and operated in order to infringe the

intellectual property rights of Gucci and others.



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TrademarkRegistration

Number

Registration

DateClass / Goods

1,107,311November 28,

1978

IC 018 - wallets, purses, handbags,

shoulder bags, clutch bags, tote bags,

card cases, partly and wholly of leather,key cases, passport cases, cosmetic

cases, attach cases, valises, suitcases,

and duffles.

(Green Red GreenStripe Design)

1,122,780 July 24, 1979


shoulder bags, clutch bags, tote bags,card cases, attach cases, valises,

suitcases, duffles, and key cases.

GUCCI 1,168,477September 8,

1981

IC 025 - neckties; scarves; belts;footwear; shirts; sweaters; coats; suits;

dressing gowns; hats; socks; dresses,

and bathing suits.

GUCCI 1,340,599 June 11, 1985IC 014 - jewelry-namely, earrings, collarbars and tie bars made wholly or in part

of precious metal.

3,039,629January 10,

2006IC 025 - footwear and belts.

3,072,549 March 28, 2006


shoulder bags, clutch bags, tote bags,business card cases, credit card cases,

partly and wholly of leather, key cases,

cosmetic cases sold empty, briefcases,attach cases, valises, suitcases, and

duffles.

3,376,129January 29,

2008

IC 006 - key rings made of metal, metal

key rings covered in leather, and metalkey rings partially covered with enamel.



business card cases, credit card cases,partly and wholly of leather, key cases,

cosmetic cases sold empty, briefcases,

attach cases, valises, suitcases andduffles.



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TrademarkRegistration

Number

Registration

DateClass / Goods

3,378,755February 5,

2008

IC 009 - eyeglass frames and sunglasses.

IC 014 - jewelry, watches, and clocks.IC 016 - address books, agendas,

notebooks, stationary in the form of

writing paper, and pens.



business card cases, credit card cases,partly and wholly of leather, key cases,

cosmetic cases sold empty, briefcases,

attach cases, valises, suitcases, and

duffles.

IC 025 - scarves, belts, footwear, shirts,

sweaters, coats, suits, dressing gowns,

and dresses.

3,391,739 March 4, 2008 IC 009 - eyeglass frames and sunglasses.

The Gucci Marks are used in connection with the manufacture and distribution of quality

goods in the categories identified above.

18. The Gucci Marks have been used in interstate commerce to identify anddistinguish Gucci's high quality goods for an extended period of time and serve as symbols of

Guccis quality, reputation, and goodwill.

19. Further, Gucci has expended substantial time, money and other resourcesdeveloping, advertising and otherwise promoting the Gucci Marks.

20. The Gucci Marks qualify as famous marks as that term is used in 15 U.S.C.1125(c)(1).



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21. Gucci has extensively used, advertised, and promoted the Gucci Marks in theUnited States in association with the sale of high quality luxury products.

22. The Gucci Marks have achieved secondary meaning as identifiers of high qualityluxury goods as a result of Guccis advertisement, promotion, and sale of such goods thereunder.

23. As a result of Guccis efforts, members of the consuming public readily identifymerchandise bearing the Gucci Marks as being high quality merchandise sponsored and

approved by Gucci.

24. Gucci has carefully monitored and policed the use of the Gucci Marks and hasnever assigned or licensed the Gucci Marks to any of the Defendants in this matter.

25. Genuine goods bearing the Gucci Marks are widely legitimately advertised andpromoted by Gucci and unrelated third parties via the Internet. Over the course of the past five

to seven years, visibility on the Internet, particularly via Internet search engines such as Google,

Yahoo!, and Bing has become increasingly important to Guccis overall marketing and consumer

education efforts. Thus, Gucci expends significant monetary resources on Internet marketing and

consumer education, including search engine optimization (SEO) strategies. Those strategies

allow Gucci to fairly and legitimately educate consumers about the value associated with the

Gucci Marks and the goods sold thereunder.

COMMON FACTUAL ALLEGATIONS

Defendants Infringing Acts

26. Upon information and belief, Defendants are promoting and advertising,distributing, selling and/or offering for sale goods in interstate commerce that bear counterfeit

and confusingly similar imitations of the Gucci Marks, including, without limitation, handbags,

wallets, shoulder bags, duffel bags, cosmetic cases, shoes, belts, sunglasses, watches, jewelry,



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and infringements of the Gucci Marks. Specifically, the Defendants are using counterfeits of

Guccis famous name and the Gucci Marks in order to make their websites selling illegal goods

appear more relevant and attractive to search engines across an array of search terms. By their

actions, Defendants have created an illegal marketplace operating in parallel to the legitimate

marketplace for genuine Gucci goods. Defendants are causing concurrent and indivisible harm to

Gucci and the consuming public by (i) depriving Gucci of its right to fairly compete for space

within search engine results and reducing the visibility of Guccis genuine goods on the World

Wide Web, (ii) causing an overall degradation of the value of the goodwill associated with the

Gucci Marks and, (iii) increasing Guccis overall cost to market its goods and educate consumers

about its brand via the Internet, and (iv) maintaining an illegal marketplace enterprise which

perpetuates the ability of Defendants and future entrants to that marketplace to confuse

consumers and harm Gucci with impunity.

30. Upon information and belief, Defendants are concurrently targeting theircounterfeiting and infringing activities toward consumers and causing harm within this judicial

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

and the consuming public for Defendants own benefit.

31. Upon information and belief, at all times relevant hereto, Defendants in this actionhad full knowledge of Guccis ownership of the Gucci Marks, including its exclusive right to use

and license such intellectual property and the goodwill associated therewith.

32. Defendants use of the Gucci Marks, including the promotion and advertisement,reproduction, distribution, sale, and offering for sale of Defendants Goods, is without Guccis

consent or authorization.



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33. Defendants are engaging in the above-described illegal counterfeiting andinfringing activities knowingly and intentionally or with reckless disregard or willful blindness to

Guccis rights for the purpose of trading on Guccis goodwill and reputation. If Defendants

intentional counterfeiting and infringing activities are not preliminarily and permanently

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

34. Defendants above identified infringing activities are likely to cause confusion,deception, and mistake in the minds of consumers, the public, and the trade 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 Gucci and Defendants Counterfeit Goods, which there is not.

35. Further, upon information and belief, Defendant galaxyayhandbags.com hasregistered at least seventeen (17) of the Subject Domain Names, using marks which are nearly

identical and/or confusingly similar to at least one of the Gucci Marks (collectively the

Infringing Subject Domain Names). The Infringing Subject Domain Names are set forth on

Schedule B hereto.

36. Defendants do not have, nor have they ever had, the right or authority to use theGucci Marks. Further, the Gucci Marks have never been assigned or licensed to be used on any

of the websites operating under the Infringing Subject Domain Names.

37. Upon information and belief, Defendants have provided false and/or misleadingcontact information when applying for the registration of the Infringing Subject Domain Names,

or have intentionally failed to maintain accurate contact information with respect to the

registration of the Infringing Subject Domain Names.



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38. Upon information and belief, Defendants have never used any of the InfringingSubject Domain Names in connection with a bona fide offering of goods or services.

39. Upon information and belief, Defendants have not made any bona fide non-commercial or fair use of the Gucci Marks on a website accessible under any of the Infringing

Subject Domain Names.

40. Upon information and belief, Defendants have intentionally incorporated theGucci Marks in their domain names to divert consumers looking for Guccis Internet website to

their own Internet websites for commercial gain.

41.

Upon information and belief, each Defendant knows of and has intentionally

joined the alleged civil conspiracy and has engaged in overt tortious acts intended to further the

conspiracy. Upon information and belief, the agreement to engage in the alleged civil conspiracy

is express between some of Defendants and may be properly inferred as to some Defendants

based upon the nature of their actions, the relationship between them and their mutual interests in

creating an illegal marketplace for counterfeit branded goods.

42. Given the visibility of Defendants various websites and the similarity of theiractions, including their SEO activities, it is clear Defendants cannot help but know of each

others existence and intend to participate in the conspiracy to destroy Guccis legitimate

marketplace through the maintenance and furtherance of their illegal marketplace using the

World Wide Web.

43. Although some of the Defendants may be acting independently, they mayproperly be deemed to be acting in concert because they are combining the force of their actions

to multiply the harm caused to Gucci.

44. Gucci has no adequate remedy at law.



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45. Gucci is suffering irreparable and indivisible injury and harm as a result ofDefendants unauthorized and wrongful use of the Gucci Marks. If Defendants counterfeiting,

infringing, cybersquatting, unfairly competitive activities, and their illegal marketplace enterprise

are not preliminarily and permanently enjoined by this Court, Gucci and the consuming public

will continue to be harmed.

46. The injury and harm sustained by Gucci has been directly and proximately causedby Defendants wrongful reproduction, use, advertisement, promotion, offers to sell, and sale of

their Counterfeit Goods, and by the creation, maintenance, and very existence of the Defendants

illegal marketplace enterprise.

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

47. Gucci hereby adopts and re-alleges the allegations set forth in Paragraphs 1through 46 above.

48. This is an action for trademark counterfeiting and infringement againstDefendants based on their use of counterfeits and confusingly similar imitations of the Gucci

Marks in commerce in connection with the promotion, advertisement, distribution, sale and/or

offering for sale of the Counterfeit Goods.

49. Defendants are promoting and otherwise advertising, selling, offering for sale,and distributing at least handbags, wallets, shoulder bags, duffel bags, cosmetic cases, shoes,

belts, sunglasses, watches, jewelry, and hats using counterfeits and infringements of one or more

of the Gucci Marks. Defendants are continuously infringing and inducing others to infringe the

Gucci Marks by using them to advertise, promote, and sell counterfeit and infringing handbags,

wallets, shoulder bags, duffel bags, cosmetic cases, shoes, belts, sunglasses, watches, jewelry,

and hats.



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including words or other symbols and trade dress which tend to falsely describe or represent such

goods and have caused such goods to enter into commerce with full knowledge of the falsity of

such designations of origin and such descriptions and representations, all to Guccis detriment.

58. Defendants have authorized infringing uses of the Gucci Marks in Defendantsadvertisement and promotion of their counterfeit and infringing handbags, wallets, shoulder

bags, duffel bags, cosmetic cases, shoes, belts, sunglasses, watches, jewelry, and hats.

Defendants have misrepresented to members of the consuming public that the Counterfeit Goods

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

59.

Additionally, Defendants are using counterfeits and infringements of the Gucci

Marks in order to unfairly compete with Gucci and others for space within search engine organic

results, thereby jointly depriving Gucci of a valuable marketing and educational tool, which

would otherwise be available to Gucci, and reducing the visibility of Guccis genuine goods on

the World Wide Web.

60. Defendants above-described actions are in violation of Section 43(a) of theLanham Act, 15 U.S.C. 1125(a).

61. Gucci has sustained indivisible injury and harm caused by Defendants concurrentconduct, and absent an entry of an injunction by this Court, Gucci will continue to suffer

irreparable injury to its goodwill and business reputation.

COUNT III - CLAIM FOR RELIEF FOR CYBERSQUATTING

UNDER 43(d) OF THE LANHAM ACT, 15 U.S.C. 1125(d)




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63. Upon information and belief, Defendants have acted with the bad faith intent toprofit from the Gucci Marks and the goodwill associated with the Gucci Marks by registering the

Infringing Subject Domain Names.

64. The Gucci Marks were distinctive and famous at the time Defendants registeredthe Infringing Subject Domain Names.

65. The Infringing Subject Domain Names are identical to, confusingly similar to, ordilutive of at least one of the Gucci Marks

66. Defendants actions constitute cybersquatting in violation of 43(d) of theLanham Act, 15 U.S.C. 1125(d).

67. Gucci has suffered and will continue to suffer irreparable injury due to the abovedescribed activities of Defendants if Defendants are not preliminary and permanently enjoined.

COUNT IV - COMMON LAW UNFAIR COMPETITION


69. This is an action against Defendants based on their (i) manufacture, promotion,advertisement, distribution, sale and/or offering for sale of goods bearing marks which are

virtually identical, both visually and phonetically, to the Gucci Marks, and (ii) creation and

maintenance of an illegal, ongoing marketplace enterprise operating in parallel to the legitimate

marketplace in which Gucci sells its genuine goods, in violation of Floridas common law of

unfair competition.

70. Specifically, Defendants are promoting and otherwise advertising, selling,offering for sale and distributing infringing and counterfeit handbags, wallets, shoulder bags,

duffel bags, cosmetic cases, shoes, belts, sunglasses, watches, jewelry, and hats. Defendants are



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associated with Gucci; from using any reproduction, counterfeit, copy, or colorable imitation of

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

sold by Defendants, including, without limitation, handbags, wallets, shoulder bags, duffel bags,

cosmetic cases, shoes, belts, sunglasses, watches, jewelry, and hats; 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 Gucci, or in any way endorsed by Gucci and from offering such goods in

commerce; from engaging in search engine optimization strategies using colorable imitations of

Guccis name or trademarks; and from otherwise unfairly competing with Gucci.

b. Entry of an order requiring the Subject Domain Names, and any otherdomain names being used by Defendants to engage in the business of marketing, offering to sell,

and/or selling goods bearing counterfeits and infringements of the Gucci Marks to be disabled

and/or immediately transferred by Defendants, their Registrars and/or the Registries to Guccis

control.

c. Entry of an Order that, upon Guccis request, the top level domain (TLD)Registry for each of the Subject Domain Names or their 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 maintained by the Registries which link the

Subject Domain Names to the IP address where the associated websites are hosted.

d. Entry of an Order that, upon Guccis request, any Internet search engines,Web hosts, domain-name registrars and domain-name registries or administrators which are

provided with notice of the injunction, cease facilitating access to any or all websites through



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which Defendants engage in the promotion, offering for sale and/or sale of goods bearing

counterfeits and/or infringements of the Gucci Marks.

f. Entry of an Order that, upon Guccis request, the Internet Corporation forAssigned Names and Numbers (ICANN) shall take all actions necessary to ensure that the top

level domain Registries or their administrators responsible for the Subject Domain Names

facilitate the transfer and/or disable the Subject Domain Names.

g. Entry of an award of Guccis costs and reasonable attorneys fees andinvestigative fees associated with bringing this action.

h.

Entry of an Order for any further relief as the Court may deem just and

proper.

DATED: November 3, 2012. Respectfully submitted,

STEPHEN M. GAFFIGAN, P.A.

By: ____s:/smgaffigan/__________Stephen M. Gaffigan (Fla. Bar No. 025844)

Virgilio Gigante (Fla. Bar No. 082635)401 East Las Olas Blvd., #130-453

Ft. Lauderdale, Florida 33301

Telephone: (954) 767-4819Facsimile: (954) 767-4821

E-mail: [email protected]

E-mail: [email protected]

Attorneys for Plaintiff

GUCCI AMERICA, INC.



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SCHEDULE A

DEFENDANT GALAXYAYHANDBAGS.COMS SUBJECT DOMAIN NAMES

SUBJECT DOMAIN NAME:

168bao.com

51bvlgari.com

8-lv.com

anyahindmarchtw.com

aura-c.com

australiagucci.net

bag48.com

bags-2012.com

bagsdiscount.net

bags-marks.com

bally2010.net

bananatp.com

bananebao.com

baobao2099.net

bolsosonline.biz

borsedimarcamilano.com

borseonlineitalia.com

brandreplicahandbags.com

brandshandbagsoutlet.com

cheapbagsonline.org

cheapbagstock.comcheapguccihandbagd.net

cheapgucciluggagesetsin.com

cheap-handbagssales.com

cheap-leather-handbags.com

cherrycherry.biz

cherrycherry.kr

ckzhongwen.com

classicbagssale.net

coach-tw9.com

constellation2011.comcoolbagmall.com

coolbagstore.com

copynara.me

dlk-fashion.com

ec2have.com

eluxury-shop.net



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evogue-collections.com

foulards-socks.com

galaxyayhandbags.com

goodpradahandbags.com

guccibagsaustralia.biz

guccibagsmalaysia.biz

guccibagsoutletsellers.com

guccibags-uk.info

guccihandbagsmalaysia.biz

guccihandbagsuk2012.org

gucci-lovelove.net

guccisaustralia.biz

guccisfactory-outlets.com

gucci-t999.netgucci-tw9.com

gucoutlotzw.com

handbagscelebrities.com

hk-gucci.com

hklafemme.com

hotguccibags.com

i-love-lv.com

jansporttw.com

joyluxury.net

jp-saifu.comkinazstores.com

kitsontw.com

knockoffhandbagss.com

laboom7.com

livestw.com

longineslangqin.com

louis-vuitton-chicago.com

louis-vuitton-hawaii.com

lovehermeshandbags.com

lovelifetw.com

love-saifu.com

love-saifujp.com

luxcindy.net

lux-enny.com

luxury-bag.net

luxuryladieshandbags.com



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luxurystores.org

luxurywill.com

luxwing.co.kr

lvaoo.com

lvcoo.com

magynvxie.com

midnjusa.com

mixibag.com

montre-tie.com

mybagsoutlets.com

mydiscountbag.net

mydiscountsbag.com

nonstory.co

nonstory.sonutsgucci.com

oz-sw.com

pradabaglist.com

pradabags2012.com

prezziscontate.com

purple-j.com

rainbow-brandfji222.com

sacsmodedes.com

sale-eluxury.com

shopbargainbags.comsitoufficialecomprare.com

soldesprix2012.com

story123.net

taohandbags.com

taschenbieten.com

tatababytw.com

topreplicabag.com

topsaifu.com

topssaifu.com

uniquebagstyle.com

uybags.com

vaskorsweden.com

vaxshop.com

watch-elite.com

wbrandbagss.com

wholesalehandbag007.com



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xinkuanbao.com

yn7-prada.net

yosmall.com



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SCHEDULE B

DEFENDANT GALAXYAYHANDBAGS.COMS

INFRINGING SUBJECT DOMAIN NAMES

DOMAIN NAME:

cheapguccihandbagd.netcheapgucciluggagesetsin.com

guccibagsaustralia.biz

australiagucci.net

guccibagsmalaysia.biz

guccibagsoutletsellers.com

guccibags-uk.info

guccihandbagsmalaysia.biz

guccihandbagsuk2012.org

gucci-lovelove.net

guccisaustralia.biz

guccisfactory-outlets.com

gucci-t999.net

gucci-tw9.com

hk-gucci.com

hotguccibags.com

nutsgucci.com


gucci v. galaxy handbags.com

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