1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

5. I also accessed the blog style Internet websites operating under the domain names
cheaphandbagsforyou.com, cheaptiffany1837.com, designerhandbags2009.com,
dhgatewholesale.net, dropshipbagsonline.com, dropshippinghandbags.com, fashionlvbags.com,
flouisvuitton.com, handbags36.com, handbags125.com, handbags118.com, handbags885.com,
handbagsavvy.com, handbagsshop11.com, highlouisvuitton.com, holleybags.org,
honeyhandbags.net, louisvuitton2you.com, louisvuittonbagsfake.com, louisvuittonme2.com,
multicolorbags8.com, nanihandbags.com, numberhandbags.com, onlyyoubags.com,
replica8bags.net, replicabagsmart.com,replicabagsonsale.com, replicahandbags18.com,
tootoobags.com, toplouisvuittonbags.com, watches26.com, watches147.com, and
shoesshop16.com (the “Blog Style Domain Names”), which Defendant uses to provide support
and direct customer traffic to the fully interactive websites operating under some of the Subject
Domain Names. Specifically, the blog style websites use the Gucci Marks to promote and
provide a link to Defendant’s websites which sell and offer for sale for sale counterfeit Gucci
branded products. True and correct copies of the relevant pages from the Internet websites
operating under the Blog Style Domain Names together with the Outbound Link Report are
attached hereto as Composite Exhibit 1.
6. After the Complaint in this action was filed and served on Defendant, Plaintiff
learned Defendant was continuing to wrongfully use the trademarks at issue by advertising and
offering for sale various products under Gucci’s trademarks without authorization via the
Internet websites operating under the domain names buy4cheaps.com, fabricgucci.com,
christian-louboutin-booties.com, replica-bags.uk.com, and softservering.com (the “Additional
Subject Domain Names”). I accessed the Internet websites operating under the Additional
Subject Domain Names. Upon accessing the websites, I was able to browse the online stores for
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