2022-cv-00805

COMPLAINT filed by Bulgari, S.p.A.; Filing fee $ 402, receipt number 0752-19155188.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. under seal regarding complaint[1]

MOTION by Plaintiff Bulgari, S.p.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bulgari, S.p.A.

Notice of Claims Involving Trademarks by Bulgari, S.p.A.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Abby Marie Neu

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Martin Francis Trainor

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff Bulgari, S.p.A. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Bulgari, S.p.A. in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Laurence Morel-Chevillet regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Exhibit 5, Parts 1-2 regarding declaration 16

Exhibit 5-1

Exhibit 5-2

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Exhibit 6 regarding declaration 16

MOTION by Plaintiff Bulgari, S.p.A. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Bulgari, S.p.A. in support of motion for miscellaneous relief 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

Exhibit 1

Exhibit 2

Exhibit 3

EXHIBIT by Plaintiff Bulgari, S.p.A. Exhibit 1 regarding MOTION by Plaintiff Bulgari, S.p.A. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery 13

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's motion for leave to file under seal 3 is granted.Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names,a temporary asset restraint, and expedited discovery 13 is granted. Plaintiff's motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 19 is granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Ronald A. Guzman on 2/17/2022. Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Bulgari, S.p.A. (Document not scanned)

MOTION by Attorney Martin F. Trainor to withdraw as attorney for Bulgari, S.p.A. No party information provided

MINUTE entry before the Honorable Ronald A. Guzman: Attorney Martin Francis Trainor's motion to withdraw as counsel for Plaintiff [26] is granted. Attorney Martin Francis Trainor terminated. Mailed notice.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Marcella Deshonda Slay

MOTION by Plaintiff Bulgari, S.p.A. for extension of time of Temporary Restraining Order

MEMORANDUM by Bulgari, S.p.A. in support of extension of time 29

(Declaration of Abby Neu)

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's ex parte motion to extend the temporary restraining order by a period of fourteen (14) days until March 17, 2022 29 is granted. Mailed notice.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Allyson M. Martin

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 3/14/2022, answer due 4/4/2022.

Declaration of Allyson Martin

Exhibit A

MOTION by Plaintiff Bulgari, S.p.A. for preliminary injunction, MOTION by Plaintiff Bulgari, S.p.A. for extension of time of Temporary Restraining Order

Exhibit 1

Exhibit 2

MEMORANDUM by Bulgari, S.p.A. in support of motion for preliminary injunction, extension of time[34]

Declaration of Allyson Martin

Exhibit 1

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 3/24/2022 at 11:00 a.m. as to Plaintiff's motion for entry of a preliminary injunction and to extend the temporary restraining order [34]. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MOTION by Attorney Abby M. Neu to withdraw as attorney for Bulgari, S.p.A. No party information provided

MINUTE entry before the Honorable Ronald A. Guzman: Attorney Abby Marie Neu's motion to withdraw as counsel for Plaintiff 37 is granted. Attorney Abby Marie Neu terminated. Mailed notice.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Jake Michael Christensen

MINUTE entry before the Honorable Ronald A. Guzman: On the Court's own motion, motion hearing set for 3/24/2022 at 11:00 a.m. is stricken and reset to 3/24/2022 at 10:30 a.m. (TIME CHANGE ONLY). The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held on 3/24/2022 regarding motion for preliminary injunction [34]. Motion for preliminary injunction [34] is granted. Enter order. Status hearing set for 5/10/2022 at 10:15 a.m. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns & Crain, Ltd is ordered to add all defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov /_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Ronald A. Guzman on 3/24/2022. Mailed notice.

NEW PARTIES: Guigang Senmeilang Leather Manufacturing Co., Ltd., Hangzhou Junyi Trading Co., Ltd., Dongguan Odian Jewelry Co., Ltd., Yiwu Hengcan Bag Co., Ltd., DODO&HIHANG Official Store, K2 Store, CHUPERMORE factory Store, Smily0630 Store, Shop5113120 Store, CHSXY Official Store, Shop5297001 Store, Vnelstyle Franchise Store, Wansen Bags factory Store, PS Digital Store, Tengci Store, Fierce Wind Store, BEWEY Store, LAYA JEWELRY Official Store, Shop911194014 Store, MAOYUHONG Store, Meirenyi Store, Akeyon Oversea Bag Store, TrendyBags Store, Belinka Store, CHSANATO Official Store, MOERWIN Store, good shopping888 Store, Shop4475035 Store, Shop5840104 Store, Shop910570073 Store, xi hai store, hongbo industrial group, GYMLP, Yuxubaihuo, juyiyu, AR7AHHY659Y6R, TH store, citylights, lyalove007 Store, haoshuai1, leochan16 Store, hello_watch Store, kkhhey Store, neideng Store, neideng, cegui Store, xingma Store, huawanwei Store, huangrongguojing1986, cyc1222, queensbags Store, a201899 Store, Wholesalebear Store, yiyu22, jingyu22, nianyue99, topclone_watch Store, prettypersuasion Store, hougedianpu Store, fjking Store, designer handbags Store, discountstore2015, nice_suppliers Store, goodad Store, hlwyluck, lovely0505, bestbagshoe, designerbagschina Store, zy51861 Store, dp02, kooduyins, maskfashiondate, weaselshop, lqf1688 Store, qianqilegou, nainaixii, jeffgreen Store, boao513112 Store, jackn393 Store, ztycase Store, shoes_nbasports Store, ztycase168 Store, babyhouse2020, xy888999 Store, Luxury bags Store, tototopjewelry, xinfeng55 Store, ccjewellery Store, ahkoanqgwin, shuanggua55 Store, wengua55 Store, jiagua55 Store, dealsbags, linnab, amos3c, good_bags789 Store, lianquan007, mxcz777 Store, qiaoye_bag1, telfar Store, zy678, zhibin02 Store, liansuo Store, lianlei Store, liandai Store, lianmian Store, lianta Store, liangu Store, lianmao Store, pailian Store, lianqun Store, runningdhgateo, designer_bags_I Store, luxurybags3, ggbags625 Store, designer_qq Store, mhhao668renrs Store, diyvanssneakers Store, good_bags987 Store, rain6rainbow Store, handbagxxx Store, oudium Store, geigeiskr Store, Rashord, luxury-mercury.com, taxidodo.com, DomainAbuse@service.aliyun.com, abuse@1api.net, pw-6b4e7b007f7e0019c94c07b1f396252e@privacyguardian.org, domainabuse@tucows.com, reg_18868130@whoisprotection.cc and abuse@dnspod.com added to case caption.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Justin Tyler Joseph

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to a certain Defendant

MOTION by Plaintiff Bulgari, S.p.A. for entry of default, MOTION by Plaintiff Bulgari, S.p.A. for default judgment as to all Defendants

Exhibit 1

(Exhibit 2)

MEMORANDUM by Bulgari, S.p.A. in support of motion for entry of default, motion for default judgment 45

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 46

(Exhibit 1)

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 5/10/2022 at 10:15 a.m. as to Plaintiff's motion for entry of default and default judgment 45. The hearing will be via telephone conference. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 1246152. Counsel of record will receive an email the day before the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Kasey Leigh Ewald

MINUTE entry before the Honorable Ronald A. Guzman: Status and motion hearings held. The parties report on the status of service of the notice of motion for default. The Court has reviewed the filings in this case and has previously reviewed filings for the temporary restraining order and the preliminary injunction order. The Court finds, as it has in the past, that it has jurisdiction over the Schedule A Defendants as they directly target their business activities towards consumers in the United States including Illinois. The Court further finds that the evidence submitted in support of this motion and the previously granted motion for a temporary restraining order establishes that the Plaintiffs have demonstrated a likelihood of success on the merits that the Plaintiff is likely to suffer irreparable harm due to a likelihood of confusion as to the origin or sponsorship of the Defendant's products; resulting in diminished goodwill, loss of reputation and brand confidence, loss of exclusivity, and future loss of sales. Because monetary damages cannot adequately repair loss of reputation or goodwill and brand confidence, the Plaintiffs have established an inadequate remedy at law. Therefore, Plaintiff's motion for entry of default and default judgment (doc. #[45]) is granted. Mailed notice.

MINUTE entry before the Honorable Ronald A. Guzman:Enter Default Judgment Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Ronald A. Guzman on 5/10/2022. (Exhibits). Mailed notice.

ENTERED JUDGMENT.Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

NOTICE of withdrawal of bond 25 by John Summerfield

FULL SATISFACTION of Judgment regarding order 52 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendant