2023-cv-01403

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 402, receipt number BILNDC-20415559.

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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 Trevor Christian Talhami

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Shelia M. Finnegan. 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.

REQUEST for Clerk of Court to refund filing fee in the amount of 402.00, receipt no. AILNDC-20415559, regarding complaint[1]

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

AMENDED complaint by Chrome Hearts LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

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SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Amended Schedule A regarding amended complaint, [14]

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

MEMORANDUM by Chrome Hearts LLC in support of motion for temporary restraining order[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

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DECLARATION of Mario Lejtman regarding memorandum in support of motion[17]

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SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Part 1 regarding declaration[19]

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[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

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REFUND PROCESSED re REQUEST for Clerk of Court to refund filing fee in the amount of 402.00, receipt no. AILNDC-20415559.

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion [16] for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 15 U.S.C. § 1117(a), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only "prove defendant's sales only; defendant must prove all elements of costs or deduction claimed." 15 U.S.C. § 1117(a). To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [3] for leave to file under seal is granted in light of the asset-restraint goal. By 03/21/2023, the Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the name of Defendant and omitting Amended Schedule A). The Plaintiff's motion [21] for electronic service of process is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 03/31/2023 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 03/24/2023. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 03/14/2023. Emailed notice

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

BOND in the amount of $1,000.00 check, Receipt No. 4624284043, posted by Greer Burns & Crain LTD for Chrome Hearts LLC.

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

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MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[27]

Declaration of Rachel S. Miller

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SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/23/2023, answer due 4/13/2023.

Declaration of Trevor C. Talhami

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MINUTE entry before the Honorable Edmond E. Chang: In light of the same facts and circumstances that justified entry of the TRO, the motion for preliminary injunction 27 is granted. With the answer deadline of 04/13/2023, R. 29, the tracking status hearing of 03/31/2023 is reset to 04/28/2023 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 04/20/2023. If the Defendant does not file a timely answer, then the Defendant shall be deemed in default and the Plaintiff shall file a motion for default judgment on or before 04/20/2023 instead. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 03/24/2023. Emailed notice

NEW PARTIES: yanbanby added to case caption.

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

MINUTE entry before the Honorable Edmond E. Chang: Pursuant to the notice of voluntary dismissal, under Federal Rule of Civil Procedure 41(a)(1)(A)(i), the case is dismissed without prejudice and with full leave to reinstate via motion filed on or before 12/26/2023. Status hearing of 04/28/2023 is vacated. Civil case terminated. Emailed notice

MOTION by Plaintiff Chrome Hearts LLC for Release of Bond

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for miscellaneous relief[34] before Honorable Edmond E. Chang on 8/26/2025 at 08:30 AM.

ORDER TO RELEASE BOND TO PLAINTIFF Signed by the Honorable Edmond E. Chang on 08/25/2025: The one thousand dollar ($1,000) cash bond, including the interest, if any, and minus the registry fee, posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Emailed notice

MOTION by Plaintiff Chrome Hearts LLC to amend/correct order on motion for miscellaneous relief, terminate hearings, [36]

MINUTE entry before the Honorable Edmond E. Chang: Motion to release bond [37] is granted. Enter Order. Motion hearing date is stricken. Mailed notice

ORDER To Release Bond to Plaintiff signed by the Honorable Edmond E. Chang on 9/18/2025. Mailed notice