2023-cv-03289

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 402, receipt number AILNDC-20670723.

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

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.

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment.

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

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 13

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Mario Lejtman regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1 - 5 regarding declaration 16

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

(Exhibit 5-5)

MOTION by Plaintiff Chrome Hearts LLC for 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)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed Plaintiff's pending Motion for Temporary Restraining Order 13, along with the motion to seal and for electronic service. These motions are under advisement. The Court will require a bond of $1,000 per defendant in this case. Plaintiff may, though is not required to, re-file the motion for TRO, and in any event Plaintiff shall re-submit to the Court's proposed order box a proposed TRO order revising the total amount of bond in compliance with this order. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13 is granted (as modified). Plaintiff's motion for electronic service of process 18 and motion for leave to file under seal 3 are granted. Enter Sealed Temporary Restraining Order. Telephonic status hearing set for 6/26/23 at 9:30am. Parties should call 866-434-5269; access code 3751971. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 6/9/2023. Mailed notice.

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

SURETY BOND in the amount of $ 104,000 posted by Chrome Hearts LLC. (Document not Postmarked)

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[25]

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 6/20/2023, answer due 7/11/2023.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's Motion for preliminary injunction as to certain Defendants [25] is granted. Telephonic status hearing set for 6/26/23 is stricken. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 6/21/2023. Mailed notice.

NEW PARTIES: Guangzhou Jiuyi Electronics Co., Ltd, Shanghai Houpai Industrial Co., Ltd., Wuhan Infini Jewelry Co., Ltd., Z M 3C Accessories Wholesale Store, A2OBDTYYQ226QR, A2RRZXW06OMXNT, Aboony, Across the earth, Albosss, AMuuxi, baiyuanwan, chengxingbaijia, chunsheng us, colorful case case, Dana Nail, DENG LIANG, dengyongbodedian, di qiu cun shang dian, DongYuLiuYue, duhuicierqikejiyouxi, euidAC, fgiVbs, Fshdy, Ghdsbcw, Gstgytw, haikoulilixinmaoyishanghang, haikoushiqilongshangwuyouxiangongsi, haikouxinjinfanshangmaoyouxiangongsi, haikouyehuashangmaoyouxiangongsi, Happycat Joycat, hotpot-us, HU YUE QING, iHome us, JIAO ZHI JIE, jinxian us, Kliker Store, Lilisd, Lucky Huan, LUO ZHEN YU, LV YANJIANG, MEILANYE, ONEETIS, ONLYKXY, Poseidonstore, quanbiranhuanbaokeji, rt594TES, ruandoudoumaoyi, SCWHCDUS, taiju, V Kitchen-US, wangcase, wanzhitu store, We Do Hair, wei sheng da xiang bao, WEN HAI KUN, WenRuo, WONDERFEEL, WU QUAN FENG, xiangbokuajin, xinliyuan, Xirgo, XUANWANG, yadi-us, yan jian yan, YEOU, Yifen-US, youshushop, YUAN HONGJUAN, yuyu us, ZHANG YILONG, zhenhangmaoyi, zhenyuejin, zhu haius, Zuzu Nails-us, aahs-2, abolmaxxfashion, chenxin668, chouji_98, cuanga87, deathpast951, deyunclub, deyunstore, gauze5, goulu0_74, hangzhouzhanlan88852, iqthdf, jearq44, linq-96, longting15, makeuamazing, makeushine, minglishengwu, mylittlef-0, oert-7, q43785_62, qiantangcommerce, wuhuainingj370_6, xiangfe45, xiaoj90, xuewa_65, yanzi43, kira_bags2, Dornail and lingmentan0 added to case caption.

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

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

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/10/2023, answer due 7/31/2023.

Declaration of Trevor C. Talhami

Exhibit A

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

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

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for entry of default, motion for default judgment 34

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 35

(Exhibit 1)

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

MINUTE entry before the Honorable Mary M. Rowland: The Court is in receipt of Plaintiffs' motion for default judgment [34]. The motion is under advisement. The Court will require a supplemental report to the default judgment motion that identifies: (1) all accounts associated with Defendants identified in Schedule A; (2) whether the accounts are frozen; and (3) the amounts in each account. If sealing any information is required, Plaintiffs may file an accompanying motion to seal. Plaintiffs' supplemental report shall be filed on or before 8/24/23. Mailed notice.

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

Supplemental Report Regarding Plaintiff's Motion for Entry of Default and Default Judgment by Chrome Hearts LLC pursuant to 38

Exhibit 1

(Exhibit A)

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

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion for default judgment [34] is granted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 8/25/2023. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MOTION by Plaintiff Chrome Hearts LLC to vacate Default Judgment and Dismiss Certain Defendant, Agreed

(Exhibit A)

NOTICE of withdrawal of bond [24] by John Summerfield. (Attachment) (Received at the Intake Counter on 03/29/2024)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's Motion to vacate default judgment and dismiss with prejudice 45 is granted. Default judgment against Defendant No. 2, Shanghai Houpai Industrial Co., Ltd. is vacated. Case against Shanghai Houpai Industrial Co., Ltd. Dismissed with prejudice. Mailed notice.