2022-cv-04487

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 402, receipt number AILNDC-19770744.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Schedule A regarding complaint 1

MOTION by Plaintiff Chrome Hearts LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chrome Hearts LLC

Notice of Claims Involving Trademarks by Chrome Hearts LLC

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Benjamin C.R. Lockyer

CASE ASSIGNED to the Honorable Ronald A. Guzman. Designated as Magistrate Judge the Honorable Jeffrey Cummings. Case assignment: Random assignment.

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.

MOTION by Plaintiff Chrome Hearts LLC for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Chrome Hearts LLC in support of motion for temporary restraining order 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Mario Lejtman regarding memorandum in support of motion 13

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1 - 6 regarding declaration 15

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

Exhibit 5-5

(Exhibit 5-6)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 6 regarding declaration 15

MOTION by Plaintiff Chrome Hearts LLCfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Chrome Hearts LLC in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

Exhibit 2

(Exhibit 3)

MINUTE entry before the Honorable Ronald A. Guzman: Plaintiff's motions for leave to file under seal 3 and for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 12 is granted. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Ronald A. Guzman on 9/1/2022. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Chrome Hearts LLC.

MOTION by Plaintiff Chrome Hearts LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Chrome Hearts LLC in support of extension of time 24

(Declaration of Rachel S. Miller)

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 September 29, 2022 24 is granted. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER. Signed by the Honorable Ronald A. Guzman on 9/12/2022. Mailed notice.

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

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction 29

Declaration of Rachel S. Miller

(Exhibit 1)

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/26/2022, answer due 10/17/2022.

Declaration of Benjamin C.R. Lockyer

(Exhibit A)

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 9/28/2022 at 10:30 a.m. as to Plaintiff's motion for preliminary injunction 29. 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 Defendant Vrenmol by Xingyi Tao

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held on 9/28/2022 regarding Plaintiff's motion for entry of a preliminary injunction 29. As stated in open court, Defendant Vrenmol's disclosures shall be filed by the 9/29/2022. Defendant's Vrenmol's response to Plaintiff's motion for preliminary injunction 29 is due on or before 10/28/2022. Defendant's Vrenmol's answer to Plaintiff's complaint 1 is due on or before 10/10/2022. Plaintiff's motion for preliminary injunction 29 is granted. Enter Order. Status hearing set for 10/19/2022 at 10:30 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.

NEW PARTIES: Beautiful expectation Store, da xing Store, DILIAN Store, EBEVER&BEAUTY YiuKai Store, Extraordinary Store, Fardrew Store, FMILY Store, Hgh-Quality-Official Store, High Street 04 Store, HiYouMi Handmade Store, Jinzhi trading co., ltd Store, kirra's Store, Mikaro Store, MISSLIN Store, New Hope Second Store, New Hope Store, New Hope Third Store, QS Silver Jewelry Store, RingKing Store, SHILI RIVER Official Store, Shop1100182005 Store, Shop1460089 Store, Shop912625387 Store, streetwear 2 Store, Sunny Girl jewelry Store, TOMY Department Store, TWTS Store, xiaxiababy Store, ykangs Store, YOU MUST BE RICH Store, A1NE2PZCAY8UV6, A358BEU4DM5IF0, ACXOP, Adecors, Aevoule, Akofic Direct, Albosss, animacoser, Aovie, ARNOETOS, Asphire, Auzztty, beilixianwangluokeji, BIGSWEET, Blossm, Bmaple, BrainKer, Building Your Life, CANIPHA, Carlar, Changsha City Man-huang Trade Co., Ltd., Changsha Liuyang Zhike Electronic Commerce Co., Lt, Changtai Shop, CHARMSTORE, chengduqinyuxinqinwangluokejiyouxiangongsi1, CL Design, DANNEASY NAIL ART, Dedia, DongShanXianJiaDongShangMaoYouXianGongSi, DreamHouseDirect, E-ASUM, Explosion Zing, ExtractRise, Funlovin, fuqingshijiangyinyanyingjiezixingcheshanghang, FZTOPONE, Guangzhoudongchenmaoyiyouxiangongsi, GZGREAT, HaomiaoXingchen, Henan Raoge Trading Co. LTD, Henanliaozhengmaoyiyouxiangongsi, Hezhiqikeji, HFSC, HonTaiDirect, JFC, JINSHENWU-EN, junarol, Juneen, KACHIMOO Nail Art, Ksndurn, KUANSHENG, Kyzistn, Ledeak Official, LGF supermarket, LIFOOST STORE, Likada Direct, lingbang, LJinHengAMZUCM, Lovegoon, LuckYuki, LXYAAA, lzsmgs1, Manfei-Boutique, MOFEINI, MORILILI, Morningsun, NBjiuyin, New Central Store, New Changxing, Ohlove, OYANTEN-US, QianJiangShiChenMinShangMaoYouXianGongSi, Qiaoling Trade Co.,Ltd, Qimeiya, Qing Sun Co.,Ltd, RFSGKWQ TECH, shenannadedian, SJZHINENG, SMANTA., Tsangbaby-US, TTMMAA, ucharmore, Uifrmely-US, USONE Home, VANSHING NAIL ART, Vibkow-US, VIVIY-USA, Vonluxyi, Vrenmol, We Do Hair, XMKJ-GZF, XZXI-US, YingGEE, YOURSEE, YREUN, yuwei direct, zhaoaiguo002, Zkptops, ZY Store-US, adidas_Wholesale Store, baby_to Store, buycheapsy Store, carters1 Store, clothingamir Store, clothingline Store, clothniux Store, clothshengwens Store, cninga Store, cningb Store, dhgatejing Store, dhituoxigate Store, fengliaoshop Store, frae Store, gcdscloth Store, gogoclothes Store, ioctopus Store, jjduns Store, newyeargan Store, offdhwhite Store, wuling50 Store, chromeforever.com, chromeforever.co, chromegarden.shop, chromeheartshop.net, survivalsource.store and chrome-garden.com added to case caption.

(AMENDED) MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held and continued to 10/19/2022 at 10:30 a.m. as to Plaintiff's motion for entry of a preliminary injunction 29. As stated in open court, Defendant Vrenmol's disclosures shall be filed by the 9/29/2022. Defendant's Vrenmol's response to Plaintiff's motion for preliminary injunction 29 is due on or before 10/10/2022. Defendant's Vrenmol's answer to Plaintiff's complaint 1 is due on or before 10/28/2022. Plaintiff's motion for preliminary injunction 29 is granted. Enter Order. 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 9/28/2022. Mailed notice.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Guangzhou Hengyi Trade Co., Ltd, owner and operator of Vrenmol

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

MINUTE entry before the Honorable Ronald A. Guzman: On the Court's own motion, the motion hearing set for 10/19/2022 is stricken and reset to 10/26/2022 at 10:30 a.m. 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.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic motion hearing held on 10/26/2022. Status hearing set for 11/16/2022 at 9:45 a.m. This hearing may be converted into a default judgment hearing, if plaintiff is ready and provides timely notice of its intent to all defendants. 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.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

MOTION by Plaintiff Chrome Hearts LLC for entry of default, MOTION by Plaintiff Chrome Hearts LLC for default judgment as to as to all Defendants

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for entry of default, motion for default judgment 46

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

(Exhibit 1)

MINUTE entry before the Honorable Ronald A. Guzman: On the court's own motion, the status hearing set for 11/16/2022 at 9:45 a.m. is stricken and reset to 11/16/2022 at 10:00 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.

ATTORNEY Appearance for Defendant CANIPHA by Adam Edward Urbanczyk

MOTION by Defendant CANIPHA for extension of time

MINUTE entry before the Honorable Ronald A. Guzman: Motion hearing set for 11/16/2022 at 10:00 a.m. as to Plaintiff's motion for entry of default and default judgment 46. 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: Defendant CANIPHA's motion for an extension of time to November 30, 2022 to answer or otherwise plead 51 is granted. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to Certain Defendants

ATTORNEY Appearance for Defendant CANIPHA by Brian Swift

MINUTE entry before the Honorable Ronald A. Guzman: Telephonic status hearing held on 11/16/2022. Motion hearing held as to Plaintiff's motion for entry of default and default judgment 46. Plaintiff's motion for entry of default and default judgment 46 is granted as to all defendant's with the exception of Defendant Canipha. Status hearing set for 11/29/2022 at 11:00 a.m. as to the motion for entry of default and default judgment 46 as to defendant Canipha 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.

ENTERED IN ERROR. (Modified by Clerk's Office on 11/21/2022).

DEFAULT JUDGMENT ORDER. Signed by the Honorable Ronald A. Guzman on 11/18/2022. Mailed notice.

NOTICE of Correction regarding 57.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

MINUTE entry before the Honorable Ronald A. Guzman: Status hearing set for 11/29/2022 is stricken. Therefore all claims against all parties having been resolved, the case is dismissed. Civil case terminated. Mailed notice.

NOTICE of Removal Material from the Custody of the Clerk's Office byJustin R. Gaudio of the firm Greer, Burns & Crain, Ltd. by the Plaintiff regarding Bond 23. (Document Received for Docketing on 2/17/2023)

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 59 in the amount of $500,000 as to certain defendant