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`ANSW ER
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`MIAMI DIVISION
`
`CASE NO: 1:23-cv-23799
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`FILED BY
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`DEFENDANTS ANSW ER
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`JUDGE: Rodolfo Armando Ruiz 11
`UNITED STATES DISTRICT JUDGE
`
`THE SM ILEY COM PANY SPRL,
`
`Plaintiff
`Vs.
`EmbroideryMoksshop
`22 (on schedule A)
`
`Defendant
`
`Im from Ukraine, and I saw summon to the coud accidentally, by checking emeil (that I do not very often).
`l didn't informed by mail, or phone call.
`
`Cbmplaint is denied. Defendant denies the allegations presented in the first paragraph of the com plaint.
`Defendant asserts that it is not involved in promoting, selling, reproducing, offering for sale, or
`distributing goods using counterfeits or confusingly similar imitations of Smiley's trademarks and
`copyrighted works. Defendant further denies the assedion that it operates under the seller identification
`nam es Iisted in Schedule ''A'' attached hereto.
`2. Complaint is denied. Defendant denies the allegations made in the second paragraph of the complaint.
`Defendant asserts that it is not engaged in any ongoing, daily, or sustained violations of Plaintiff's
`tradem ark rights and copyrights. Defendant further denies reproducing, counterfeiting, or infringing upon
`Plaintiffs tradem arks and copyrights with the intention of confusing the consum ing public or earning
`substantial profits. Defendant disputes any assertion that its actions contribute to the erosion of
`Plaintiffs goodwill or the destruction.
`3. Complaint is denied. Defendant denies the allegations made in the third paragraph of the complaint.
`D efendant asseds that it has not engaged in any conduct that has contributed to the harm alleged by
`Plaintiff. Defendant further denies any involvem ent in counterfeiting or actions that have necessitated
`Plaintiffs expenditure of resources for tradem ark and copyright.
`
`I hereby certify that a copy hereof has been furnished by m ail to Plaintiffs attorney this 22th day of January,
`2024.
`
`Javier Sobrado, Esq.
`THE BRICKELL IP G ROUP, PLLC
`1101 Brickell Avenue, South Tower, Suite 800
`M iam i
`FL
`33131
`
`DATE: 22th January 2024
`
`Subm itted by
`
`Fred Bondarchuk
`EmbroijeryM6ksàhop
`PO Box 31
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`Case 1:23-cv-23799-RAR Document 111 Entered on FLSD Docket 02/08/2024 Page 2 of 2
`
`
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