2023-cv-02604

COMPLAINT filed by Christian Dior Couture, S.A.; Filing fee $ 402, receipt number AILNDC-20577361.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Schedule A regarding complaint[1]

MOTION by Plaintiff Christian Dior Couture, S.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Christian Dior Couture, S.A.

Notice of Claims Involving Trademarks by Christian Dior Couture, S.A.

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Sunil R. Harjan. Case assignment: Random assignment. (Text entry; no document attached.)

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. (Text entry; no document attached.)

MOTION by Plaintiff Christian Dior Couture, S.A. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Nicolas Lambert regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Exhibit 5 - Parts 1-10 regarding declaration 14

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

Exhibit 5-5

Exhibit 5-6

Exhibit 5-7

Exhibit 5-8

Exhibit 5-9

(Exhibit 5-10)

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

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for miscellaneous relief 16

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

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 11, motion for miscellaneous relief 16, motion for leave to file 3 before Honorable John Robert Blakey on 5/10/2023 at 11:00 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants Plaintiff's motion for leave to file under seal [3] and motion for leave to serve Defendants electronically [16]. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order [11]. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 5/23/2023. The 5/10/23 Notice of Motion date is stricken. Mailed notice

SEALED ORDER Signed by the Honorable John Robert Blakey on 5/9/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

MOTION by Plaintiff Christian Dior Couture, S.A. for extension of time of Temporary Restraining Order

MEMORANDUM by Christian Dior Couture, S.A. in support of extension of time 24

(Declaration of Kahlia R. Halpern)

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 24 before Honorable John Robert Blakey on 5/17/2023 at 11:00 AM.

SURETY BOND in the amount of $ 10,000 posted by Christian Dior Couture, S.A. (Document not Scanned)

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's ex parte motion 24 to extend the temporary restraining order entered 5/9/23 23. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 6/6/23. The 5/17/23 Notice of Motion date is stricken. Mailed notice

MOTION by Plaintiff Christian Dior Couture, S.A. for preliminary injunction

(Exhibit A)

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for preliminary injunction 29

Declaration of Kahlia R. Halpern

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 29 before Honorable John Robert Blakey on 5/31/2023 at 11:00 AM.

(Exhibit A)

SUMMONS Returned Executed by Christian Dior Couture, S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/25/2023, answer due 6/15/2023.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable John Robert Blakey: The Court takes Plaintiff's motion for preliminary injunction [29] under advisement, strikes the 5/31/23 Notice of Motion date, and sets the matter for hearing on 5/31/23 at noon in Courtroom 1203. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: On the Court's own motion, motion hearing previously set for 5/31/2023 at 12:00 p.m. is reset for 5/31/2023 at 1:00 p.m. (NOTE TIME CHANGE ONLY) Mailed notice

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Justin Tyler Joseph

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 5/31/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for preliminary injunction [29] is granted. Enter Preliminary Injunction Order. The Court directs the Clerk to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the Court's docket within three business days. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Status hearing set for 7/19/2023 at 11:00 a.m. in Courtroom 1203. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable John Robert Blakey on 5/31/2023. Mailed notice

NEW PARTIES: UO SANDALS Store, BEAJIU Store, Connie Store, Grail-Cos Store, Hello Hi Store, HiMeiJian Official Store, Old Flammme Store, Shop1102663606 Store, Shop1102683603 Store, Shop1102688140 Store, Shop1102721077 Store, Shop3665105 Store, Shop5260172 Store, Shop911057089 Store, Shop911063167 Store, Top Quality 7XL 8XL 9XL 10XL Store, YUGE Shoes Store, A1651X8LGKNYQW, A19PTW0QWPVACE, A1BXQMO69Z76YN, A1S9LBD5BZ4NDE, A1TKIHP5K9BCE4, A1YTXYEBQN7ZIJ, A2YB7YPV56IUHF, A3CO6QLXBK9VUK, A3L0GAMSWOGCNJ, A3MT88BYD7GQGD, A3T81YKV9S691X, ADM1GDR04ZNFQ, AiXingY, Alan-G shop, anhuisheng01, ARADIO, ARTSPRING, AUFLW9D18K47Z, awdjawipod, AZ3SBLN7HWX3K, bawew, binzhougaoxinquxiangroubaihuodian, binzhougaoxinquzhenqiuguangbaihuodian, Blosom US, chengduquanpeichenyuwenhuachuanmeiyouxiangongsi, chengdushensungushangmaoyouxiangongsi, ChengDuShiRuiRongJiaYouJiSuanJiXiaoShouYouXianGong, Chunhuan dian, CTHOMMR, DAIGUOQING, DIY Home Store, DPLZO, Eanubs, erhujiancai, Fagithe, fanmaoshangmao1, Fen Yang Shi Bing Bing Dian Nao Jian Cai Bu, Fineline Stops, foshanshijiukailukejiyouxiangongsi, Friends Rose -US, GELIVABLE, guangzhouyanjieshangmao, guilinshilinguiqujinjufuzzhuanglingshoudian, guipingshijintianzhenchenwenlonggushanshimofendian, guobaoroudedian, GUZHUYINGXINGH, Haikou Longhua Hongkang Department, HAO-YIDA, hefeiruiguishangmaoyouxiangongsi, hongrui-us, HuaAnwinYueQi, huashuodianzishangwuyouxiangongsi, jeina, JINGMENSHIDONGBAOQUYAXIANGBAIHUODIAN, JINGYANGMUZI, Jjxtsmyxss, Jsnncxc, JSTGoiu, KaiFengZhengJinShangMaoYouXianGongSi, KunMingFuZhanDianZiShangWuYouXianGongSi, LDDWLXSD, ledongcaihe, liangshanhuacongyangzhizhuanyehezuoshe, liangweidongshangmao, lihongdedianpuww, LinGaoYaPanShengWangLuoKeJiYouXianGongSi, lingfengxuan, LinXQ, LI-TAO, LiuFengLiuFeng, LiuYaodedianpu, luoyi01, mayng, MODDYS FASHION, MOUAUOM Silver Jewelry, Mowei Strict Election, NANCHANGPEIPANBENGKEJIYOUXIANGONGSI, nhyuipkd, nTSOE2, peitongkuajing, QIAN-RE, Qing Lai Yuying, qiuyandianpu, qixiashichuanghongmenyepifabu, SADHJKKHLDSAHJ, Savoy e-Commerce, shengjujixieshangwu, shilinyang, Snenig, songshanquxingyaobaihuodian, TecFredy, TeodorsJY, TIAOTIAOLONG, TINGXIN, TNLPOWER, TULAAO0, wangchangdedian, WENJIEIE, wenxinshangwu, WOKING, XIN HAN CHEN XUAN STORE, XingYiMinggMinWangLuoKeJi, yanghengdebeimeidianpu, yanhanshangmao, Yehbfed, Ygxbzm, yifengmoweiyouxiangongsi, YUEXINGMA, yujunpopengxiaopu, YunYuDianZiShangWu, YYSuniee, zouchengshimingshiwujinshangdian, zumingjindedian, Zyhyjzgcyxgs, dhone88 Store, fashionsinglestore11 Store, kang7758 Store, hcn1771, jian3632, luckylucy7969, sportscity26, tw_lucykicks, famiglistmo09, fhdo47055tt, luxury_garden, luxurybag199, luxurybag804, luxurycollection0, michelle_bags1, minerva_fashion68, my100bags.us, ofluxuryyyy, user6806077019418, user7067873616616, user78193858199, Kkapok, voguemall.site and kongzhiming9720 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to certain defendants

MOTION by Plaintiff Christian Dior Couture, S.A. for entry of default as to all Defendants, MOTION by Plaintiff Christian Dior Couture, S.A. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for entry of default, motion for default judgment, [39]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[40]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [39] before Honorable John Robert Blakey on 6/28/2023 at 11:00 AM.

Exhibit A

ATTORNEY Appearance for Defendants Alan-G shop, GELIVABLE, Savoy e-Commerce, YYSuniee, chengduquanpeichenyuwenhuachuanmeiyouxiangongsi by Adam Edward Urbanczyk

MOTION by Defendants Alan-G shop, GELIVABLE, Savoy e-Commerce, YYSuniee, chengduquanpeichenyuwenhuachuanmeiyouxiangongsi for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[44] before Honorable John Robert Blakey on 6/28/2023 at 11:00 AM.

RESPONSE by Plaintiff Christian Dior Couture, S.A. to extension of time[44]

MINUTE entry before the Honorable John Robert Blakey: The Court resets the hearings on Plaintiff's motion for entry of default and default judgment [39] and Defendants' motion for extension of time [44] from 6/28/2023 to 6/30/2023 at 11:00 AM in Courtroom 1203. The 6/28/2023 Notice of Motion dates are stricken. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: The Court grants the unopposed motion to extend time [44] filed by Defendants Alan-G shop, GELIVABLE, Savoy e-Commerce, YYSuniee, and chengduquanpeichenyuwenhuachuanmeiyouxiangongsi and orders these Defendants to respond to the complaint by 7/12/23. In light of this extension, the Court denies without prejudice Plaintiff's motion for entry of default and for default judgment [39]. The 6/30/23 motion hearing is stricken as to all motions. Mailed notice

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to Certain Defendants

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to a Certain Defendant

MOTION by Plaintiff Christian Dior Couture, S.A. for entry of default as to all Defendants, MOTION by Plaintiff Christian Dior Couture, S.A. for default judgment as to all Defendants

Exhibit 1

Exhibit A

NOTICE of Motion by Justin R. Gaudio for presentment of motion for entry of default, motion for default judgment, [51] before Honorable John Robert Blakey on 7/5/2023 at 11:00 AM.

Exhibit A

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notices of voluntary dismissal [49] and [50], Defendants (Alan-G shop 31), (chengduquanpeichenyuwenhuachuanmeiyouxiangongsi 42), (GELIVABLE 58), (TNLPOWER 112), (YYSuniee 128) and (Savoy e-Commerce 103) are dismissed without prejudice with leave to reinstate within 270 days of this order. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 7/5/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for default judgment as to all Defendants [51] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER Signed by the Honorable John Robert Blakey on 7/5/2023. Mailed notice

Notice of Withdrawal of Surety Bond [27] by Plaintiff Christian Dior Couture, S.A.'s Attorney Justin R. Gaudio. (Exhibits).

FULL SATISFACTION of Judgment regarding order[55] in the amount of $500,000 as to certain defendants

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

Closing Minute Entry dated 7/5/2023

FULL SATISFACTION of Judgment regarding order[55] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 55 in the amount of $100,000 as to certain defendant