THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CHANEL, INC., a New York corporation,
Plaintiff,
v.
DARA L. KROVETZ, an individual, and
GOLD COAST REPORTING, INC., a Florida
corporation, individually and jointly, d/b/a
jewelryandbabyblingbydara.com d/b/a jewelry
and baby bling by dara, and DOES 1-10,
Defendants.
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Case No. ________________



COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
Plaintiff, CHANEL, INC., a New York corporation ("Chanel") hereby sues Defendants,
DARA L. KROVETZ, an individual, and GOLD COAST REPORTING, INC., a Florida
corporation, individually and jointly, d/b/a jewelryandbabyblingbydara.com d/b/a jewelry and
baby bling by dara (collectively, the Gold Coast Defendants) and DOES 1-10 (collectively
Defendants). Defendants are promoting, selling, offering for sale and distributing goods
bearing counterfeits and confusingly similar imitations of Plaintiffs trademarks within this
district using at least the website operating under the domain name
jewelryandbabyblingbydara.com (the Subject Domain Name). In support of its claims,
Plaintiff alleges as follows:
JURISDICTION AND VENUE
1. This is an action pursuant to (i) 15 U.S.C. 1114, 1116, 1121 and 1125(a).
Accordingly, this Court has jurisdiction under 28 U.S.C. 1331, 1332 and 1338. Venue is
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proper in this Court pursuant 28 U.S.C. 1391 since the named Defendants reside and conduct
business in this District.
THE PARTIES
2. Chanel is a corporation duly organized under the laws of the State of New York
with its principal place of business in the United States located at Nine West 57th Street, New
York, New York 10019. Chanel is, in part, engaged in the business of manufacturing and
distributing throughout the world, including within this J udicial District, high quality clothing
products, including shoes, and mobile device covers under Federally registered trademarks,
including but not limited to , and . Chanel is the owner of all registered and common
law rights associated with the above-referenced marks as used in connection with the promotion,
advertisement and distribution of goods in the United States.
3. Gold Coast Reporting, Inc. is a corporation organized under the laws of the State
of Florida with its principal place of business located within this District at 5011 SW 114
th
Way,
Ft. Lauderdale, Florida 33301. Gold Coast is subject to personal jurisdiction in this Court.
4. Dara Krovetz is an individual, who resides and conducts business within this
District at 5011 SW 114
th
Way, Ft. Lauderdale, Florida 33301. Dara Krovetz is subject to
personal jurisdiction in this Court.
4. Upon information and belief, Gold Coast Reporting, Inc. and Dara Krovetz are
directly engaging in the sale of counterfeit and infringing products at least within this District as
alleged herein, and use the aliases jewelryandbabyblingbydara.com, and jewelry and baby
bling by dara in connection with the operation of their counterfeiting business.
5. Defendant Does 1-5 are, upon information and belief, individuals who reside
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and/or conduct substantial business within this District. Further, Does 1-5 are directly and
personally contributing to, inducing and engaging in the sale of counterfeit products as alleged
herein as partners or suppliers to the named Defendant. Chanel is presently unaware of the true
names of Does 1-5. Chanel will amend this Complaint upon discovery of the identities of such
fictitious Defendants.
6. Defendants Does 6-10 are business entities which, upon information and belief,
reside and\or conduct business within this District. Moreover, Does 6-10 are, upon information
and belief, directly engaging in the sale of counterfeit products as alleged herein as partners or
suppliers to the named Defendant. Chanel is presently unaware of the true names of Does 6-10.
Chanel will amend this Complaint upon discovery of the identities of such fictitious Defendants.
COMMON FACTUAL ALLEGATIONS
7. Chanel is the owner of all rights, including common law rights, in and to the
following trademarks protected by United States Federal Trademark Registrations:
Trademark
Registration
Number
Registration Date Class(es)/Goods

4,074,269 December 20, 2011
(Int'l Class: 9) Protective covers
for portable electronic devices,
handheld digital devices,
personal computers and cell
phones

1,241,264 J une 7, 1983
(Int'l Class: 25) Suits, jackets,
skirts, dresses, pants, blouses,
tunics, sweaters, cardigans, tee-
shirts, coats, raincoats, scarves,
shoes and boots

which are registered in International Classes 9 and 25, and are used in connection with the
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manufacture and distribution of, among other things, clothing products, including shoes, and
mobile device covers. Additionally, Chanel is the owner of all common law rights in and to the
and Marks as associated with clothing products, including shoes, mobile devices and
baby products, including pacifiers (the above-identified common law and registered marks shall
collectively be referred to herein as the Chanel Marks).
8. The Chanel Marks have been used in interstate commerce to identify and
distinguish Chanel's high quality clothing products, including shoes, mobile device covers, baby
products, including pacifiers, and other goods for an extended period of time.
9. The Chanel Marks have never been assigned or licensed to any of the Defendants
in this matter.
10. The Chanel Marks are symbols of Chanel's quality, reputation, and goodwill and
have never been abandoned.
11. Further, Chanel has expended substantial time, money and other resources
developing, advertising, and otherwise promoting the Chanel Marks. The Chanel Marks qualify
as famous marks as that term is used in 15 U.S.C. 1125(c)(1).
12. Chanel has extensively used, advertised and promoted the Chanel Marks in the
United States in association with the sale of high quality products and has carefully monitored
and policed the use of the Chanel Marks.
13. As a result of Chanels efforts, members of the consuming public readily identify
merchandise bearing the Chanel Marks, as being high quality merchandise sponsored and
approved by Chanel.
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14. Accordingly, the Chanel Marks have achieved secondary meaning as identifiers
of high quality clothing products.
15. Upon information and belief, at all times relevant hereto, the Defendants in this
action had full knowledge of Chanel's ownership of the Chanel Marks, including its exclusive
right to use and license such intellectual property and the goodwill associated therewith.
16. Chanel has discovered the Defendants are promoting and otherwise advertising,
distributing, selling and/or offering for sale counterfeit and/or infringing products, including at
least , bearing trademarks that are exact copies of the Chanel Marks (the Infringing Goods).
Specifically, the Defendants are using the Chanel Marks in the same stylized fashion, for
different quality goods.
17. The Defendants Infringing Goods are of a quality substantially different than that
of Chanels genuine goods. Despite the nature of their Infringing Goods and the knowledge they
are without authority to do so, the Defendants, upon information and belief, are actively using,
promoting and otherwise advertising, distributing, selling and/or offering for sale substantial
quantities of their Infringing Goods with the knowledge that such goods will be mistaken for the
genuine high quality products offered for sale by Chanel. The net effect of the Defendants
actions will be to result in the confusion of consumers who will believe the Defendants
Infringing Goods are genuine goods originating from and approved by Chanel.
18. The Defendants advertise their Infringing Goods for sale to the consuming public.
In so advertising these products, the Defendants use the Chanel Marks. Indeed, the Defendants
herein misappropriated Chanels advertising ideas and entire style of doing business with regard
to the advertisement and sale of Chanels genuine products. Upon information and belief, the
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misappropriation of Chanels advertising ideas in the form of the Chanel Marks has occurred, in
part, in the course of Defendants advertising activities and has been the proximate cause of
damage to Chanel.
19. Upon information and belief, the Defendants are conducting their counterfeiting
and infringing activities at least within this District and elsewhere throughout the United States.
As a result, the Defendants are defrauding Chanel and the consuming public for the Defendants
own benefit. Defendants infringement and disparagement of Chanel does not simply amount to
the wrong description of their goods or the failure of the goods to conform to the advertised
quality or performance.
20. The Defendants use of the Chanel Marks, including the promotion and
advertising, reproduction, distribution, sale and offering for sale of their Infringing Goods, is
without Chanels consent or authorization.
21. Further, the Defendants are engaging in the above-described illegal counterfeiting
and infringing activities knowing and intentionally or with reckless disregard or willful blindness
to Chanels rights for the purpose of trading on the goodwill and reputation of Chanel. If the
Defendants intentional counterfeiting and infringing activities are not permanently enjoined by
this Court, Chanel and the consuming public will continue to be damaged.
22. The Defendants above-identified infringing activities are likely to cause
confusion, deception, and mistake in the minds of consumers, the public, and the trade.
Moreover, the 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
Chanels genuine goods and the Defendants Infringing Goods.
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23. Chanel has no adequate remedy at law.
24. Chanel is suffering irreparable injury and has suffered substantial damages as a
result of the Defendants counterfeiting and infringing activities.
25. The injuries and damages sustained by Chanel have been directly and proximately
caused by the Defendants wrongful reproduction, use, advertisement, promotion, offering to
sell, and sale of their Infringing Goods.
26. Chanel has retained the undersigned counsel to represent it in this matter and is
obligated to pay said counsel a reasonable fee for such representation.
COUNT I - FEDERAL TRADEMARK INFRINGEMENT
PURSUANT TO 32 OF THE LANHAM ACT

27. Chanel hereby adopts and re-alleges the allegations set forth in Paragraphs 1
through 26 above.
28. This is an action for trademark infringement against the Defendants based on their
promotion, advertisement, distribution, sale and/or offering for sale of clothing products,
including shoes and mobile device covers using marks which are substantially similar and, in
some instances, virtually identical to one or more of the Chanel Marks.
29. Specifically, Defendants are promoting and otherwise advertising, selling,
offering for sale and distributing clothing products, including shoes and mobile device covers
bearing colorable imitations of the Chanel Marks. In so doing, the Defendants are continuously
infringing and inducing others to infringe the Chanel Marks by using them to advertise, promote,
and sell clothing products, including shoes and mobile device covers products bearing the Chanel
Marks.
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30. Defendants infringing activities are likely to cause and may actually be causing
confusion, mistake, and deception among members of the trade and the general consuming
public as to the origin and quality of Defendants goods.
31. The Defendants unlawful actions have caused and are continuing to cause
unquantifiable damages to Chanel.
32. Defendants above-described actions constitute infringement of the Chanel Marks
in violation of Chanel's rights under 32 of the Lanham Act, 15 U.S.C. 1114.
33. Chanel has suffered and will continue to suffer irreparable injury due to the above
described activities of the Defendants if the Defendants are not enjoined.
COUNT II - FEDERAL TRADEMARK COUNTERFEITING
PURSUANT TO 32 OF THE LANHAM ACT

34. Chanel hereby adopts and re-alleges the allegations set forth in Paragraphs 1
through 33 above.
35. This is an action for trademark counterfeiting against the Defendants based on
their promotion, advertisement, distribution, sale and/or offering for sale of clothing products,
including shoes and mobile device covers bearing counterfeits of one or more of the Chanel
Marks.
36. Specifically, Defendants are promoting and otherwise advertising, selling,
offering for sale and distributing at least clothing products, including shoes and mobile device
covers bearing counterfeits of the Chanel Marks. The Defendants are continuously infringing
and inducing others to infringe the Chanel Marks.
37. Defendants counterfeiting activities are likely to cause and actually are causing
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confusion, mistake, and deception among members of the trade and the general consuming
public as to the origin and quality of Defendants goods.
38. The Defendants unlawful actions have caused and are continuing to cause
unquantifiable damages to Chanel.
39. Defendants above-described illegal actions constitute counterfeiting of the
Chanel Marks in violation of Chanel's rights under 32 of the Lanham Act, 15 U.S.C. 1114.
40. Chanel has suffered and will continue to suffer irreparable injury due to the above
described activities of the Defendants if the Defendants are not enjoined.

COUNT III - FALSE DESIGNATION OF ORIGIN
PURSUANT TO 43(a) OF THE LANHAM ACT
41. Chanel hereby adopts and re-alleges the allegations set forth in Paragraphs 1
through 40 above.
42. The Defendants Infringing Goods bearing and sold under the Chanel Marks have
been widely advertised and distributed throughout the United States.
43. The Defendants Infringing Goods bearing and sold under the Chanel Marks are
different and likely inferior in quality from genuine Chanel goods. Accordingly, the Defendants
activities are likely to cause confusion in the trade and among the general public as to at least the
origin or sponsorship of the Infringing Goods.
44. The Defendants have used in connection with their sale of Infringing Goods, false
designations of origins and false descriptions and representations, including words or other
symbols and trade dress which tend to falsely describe or represent such goods and have caused
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such goods to enter into commerce with full knowledge of the falsity of such designations of
origin and such descriptions and representations, all to the detriment of Chanel.
45. Specifically, the Defendants have authorized an infringing use of the Chanel
Marks, in the Defendants advertisement and promotion of their shoes, cell phone covers, and
baby pacifiers. The Defendants have misrepresented to members of the consuming public that
the Infringing Goods being advertised and sold by them are genuine, non-infringing products.
46. The Defendants above-described actions are in violation of Section 43(a) of the
Lanham Act, 15 U.S.C. 1125(a).
47. Chanel has sustained injury and damage caused by Defendants conduct, and
absent an entry of an injunction by this Court, Chanel will continue to suffer irreparable injury to
its goodwill and business reputation as well as monetary damages.
COUNT IV - COMMON LAW TRADEMARK INFRINGEMENT

48. Chanel hereby adopts and re-alleges the allegations set forth in Paragraphs 1
through 47 above.
49. This is an action for common law trademark infringement against the Defendants
based on their promotion, advertisement, offering for sale, and sale of the Infringing Goods.
Chanel is the owner of all common law rights in and to the Chanel Marks.
50. Specifically, the Defendants are promoting and otherwise advertising, offering for
sale, selling and distributing infringing products bearing the Chanel Marks.
51. Defendants infringing activities are likely to cause and actually are causing
confusion, mistake and deception among members of the trade and the general consuming public
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as to the origin and quality of Defendants' products. Chanel has no adequate remedy at law and
is suffering damages and irreparable injury as a result of Defendants' actions.
52. Plaintiff has sustained injury and damage caused by the Defendants conduct, and
absent an entry of an injunction by this Court, Plaintiff will continue to suffer irreparable injury
to its goodwill and business reputation as well as monetary damages.
PRAYER FOR RELIEF
59. WHEREFORE, Chanel demands judgment, jointly and severally, against the
Defendants as follows:
a. Entry of a permanent injunction enjoining Defendants, their agents,
representatives, servants, employees, and all those acting in concert or participation therewith,
from manufacturing or causing to be manufactured, importing, advertising or promoting,
distributing, selling or offering to sell their Infringing Goods; from infringing, counterfeiting, or
diluting the Chanel Marks; from using the Chanel Marks, or any mark or trade dress similar
thereto, in connection with the sale of any unauthorized goods; from using any logo, trade name
or trademark or trade dress which may be calculated to falsely advertise the services or products
of the Defendants as being sponsored by, authorized by, endorsed by, or in any way associated
with Chanel; from falsely representing themselves as being connected with Chanel, through
sponsorship or association, or 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 the Defendants, or in
any way endorsed by, approved by, and/or associated with Chanel; from 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 the Defendants, including, without
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limitation, clothing products, including shoes, mobile devices, and baby products, including
pacifiers, and other goods; 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 Chanel, or in any way endorsed
by Chanel and from offering such goods in commerce; and from otherwise unfairly competing
with Chanel.
b. Entry of an Order requiring Defendants to account to and pay Chanel for
all profits and damages resulting from Defendants trademark infringement and counterfeiting
activities, and that the award to Chanel be trebled, as provided for under 15 U.S.C. 1117, or, at
Chanels election with respect to Count I, that Chanel be awarded statutory damages from each
Defendant in this matter in the amount of two million dollars ($2,000,000.00) per each
counterfeit trademark used and product sold, as provided by 15 U.S.C. 1117(c)(2) of the
Lanham Act.
c. Entry of an Order awarding Chanel damages, trebled pursuant to 15
U.S.C. 1117(a), arising out of Defendants acts of willful trademark infringement and
counterfeiting, and dilution of the Chanel Marks.
d. Entry of an award of Chanels costs and reasonable attorneys fees and
investigative fees associated with bringing this action.
e. Entry of an award of pre-judgment interest on the judgment amount.
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f. Entry of an Order for any further relief as the Court may deem just and
proper.
DATED: October 28, 2014. Respectfully submitted,
STEPHEN M. GAFFIGAN, P.A.

By:______s:/Stephen M. Gaffigan_________
Stephen M. Gaffigan (Fla. Bar No. 025844)
401 East Las Olas Blvd., Suite 130-453
Ft. Lauderdale, Florida 33301
Telephone: (954) 767-4819
Facsimile: (954) 767-4821
E-mail: [email protected]

Attorneys for Plaintiff,
Chanel, Inc.

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