2023-cv-00804

COMPLAINT filed by Bulgari, S.p.A.; Filing fee $ 402, receipt number AILNDC-20332333.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Schedule A 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 Rachel S Miller

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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

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 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 - 3 regarding declaration 16

Exhibit 5-1

Exhibit 5-2

(Exhibit 5-3)

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 18

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

Exhibit 1

(Exhibit 2)

MEMORANDUM by Bulgari, S.p.A. establishing that joinder is proper

DECLARATION of Justin R. Gaudio regarding memorandum 21

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

(Exhibit 8)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's motion for leave to file under seal 3, ex parte motion for a temporary restraining order 13, and motion for electronic service of process 18. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on April 11, 2022 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any Defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Franklin U. Valderrama on 4/6/2023. Mailed notice.

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

MOTION by Plaintiff Bulgari, S.p.A. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Bulgari, S.p.A. in support of motion for preliminary injunction[25]

Declaration of Rachel S. Miller

Exhibit 1

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/20/2023, answer due 5/11/2023.

Declaration of Trevor C. Talhami

Exhibit A

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/21/2023, answer due 5/12/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

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

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

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to Certain Defendants

BOND in the amount of $ 10,000 check, Receipt No. 4624284921, posted by Bulgari, S.p.A. (jk2,)

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 A

MEMORANDUM by Bulgari, S.p.A. in support of motion for entry of default, motion for default judgment[32]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against all remaining Defendants [32] is granted. See R. 32-1 (Exhibit A, Updated Version of Schedule A). Enter Final Default Judgment Order. The ten thousand dollar ($10,000) cash bond, including the interest minus the registry fee, posted by Bulgari is hereby released to Plaintiff's counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the cash bond previously deposited with the Clerk of the Court, plus any interest minus the registry fee, to Bulgari's counsel, Justin Gaudio, at Greer Burns & Crain Ltd, 300 South Wacker Drive, Suite 2500, Chicago IL 60606. Motion for preliminary injunction [25] is denied as moot. Civil case terminated. Emailed notice

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 5/19/2023. Emailed notice

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 5/19/2023)

FULL SATISFACTION of Judgment regarding order 36 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[36] in the amount of $200,000 as to certain defendant