2023-cv-03701

COMPLAINT filed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC; Filing fee $ 402, receipt number AILNDC-20727937.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Schedule A regarding complaint[1]

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC

Notice of Claims Involving Trademarks by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Berel Yonathan Lakovitsky

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 Andrea R. Wood. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, 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 Marc Jacobs International, LLC, Marc Jacobs Trademarks, 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 Nicolas Lambert regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Exhibit 3 - Parts 1-10 regarding declaration[15]

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Exhibit 3 - Parts 11-12 regarding declaration[15]

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, 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 Andrea R. Wood: Plaintiffs' motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery 12, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 6/22/2023 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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 Andrea R. Wood: Telephonic motion hearing held on 6/22/2023. For the reasons stated on the record, Plaintiffs' motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery [12], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2], (2) Exhibit 3, Parts 1-10 [16], and (3) Exhibit 3, Parts 11-12 [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 6/22/2023 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 7/6/2023 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 6/22/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (axk,)

SURETY BOND in the amount of $ 10,000 posted by Marc Jacobs Trademarks, LLC (Document Not Imaged) (axk,)

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of extension of time 25

(Declaration of Kahlia R. Halpern)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' ex parte motion to extend the temporary restraining order [25] is granted. The Court finds good cause to extend the Temporary Restraining Order until 7/20/2023. Telephonic status hearing set for 7/6/2023 is stricken and reset for 7/20/2023 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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 Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to a Certain Defendant

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for preliminary injunction[30]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/17/2023, answer due 8/7/2023.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [30] will be heard at the telephonic hearing set for 7/20/2023 at 10:15 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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 Andrea R. Wood: Telephonic status and motion hearing held on 7/20/2023. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 30 is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint 2, (2) Exhibit 3, Parts 1-10 16, (3) Exhibit 3, Parts 11-12 17, and (4) the sealed temporary restraining order 23. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 9/6/2023 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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 Andrea R. Wood on 7/20/2023. Mailed notice

NEW PARTIES: LiYongBo BoYong, LokiOdinson, LuckyPig, LZHSM^SU, malin store, mangsailinshangmao, Marchsan, Maychyhill, MeiChunHuaxiaodian, MeiYiShu, meiyuexishangmao, mianxianxiyunbaihuodian, MICKEY007, Minami-us, MINGHUA XIANGYE, mingliangdedianpummm, Minquan Pengjia Trading Co., Ltd, miss lily shop, Mitijiang, nanchanghefei, NANCHANGMUMENGPEIMAOYIYOUXIANGONGSI, NANCHANGZHANCUIBENGMAOYIYOUXIANGONGSI, NMMM99, Npkangyuan, ogIjuZhopn, ouzhenglan, palmzen, PAN YONG CHUN, PODACO, putianshiruifengxinshangmaoyouxiangongsi, QingXinYa, QiQiHaErShiJianHuaQuChaoShengYouQiCheYangHuZhongXi, qiulindexiaodian, QU ZHE, QUANGANGWENMING, QuickOpener, QWIUTY77, rongzhiluoshangmao, runyu US, sanmenxiashanyingshangmaoyouxiangongsi, SgoyiU(Fast Shipping 6-12 Days), Shanghai Luyaoba, shukededianpu, Silver-department-store, Stone'S Store, suixianmuxinnvzhuangdian, Sup-Market, suyi8888, Take it from me, Tan Pu Store, tanyangdexiaodian, tanzhiqiang123, TAOYU-WGXZ, Tbtopa, TEGOGAL-US, TELRTRGRHU, teranshanghang, TIANC, tianjinshixiqingquhuoshangbaihuoshanghang, TieLingXianJiuKeShiPinDian, tomato us, tongchuantuoke, TongTai, Traceback, TUAHOUS-US, tuhaohuibeimeizhan, US-WTDZW, WADON, WANG HE QING, WANG LI JUN 123, WangZhiKui123, Wanning Qihuitao Trading Co., LTD, websiterz, weiendianzishangwu, weifangsongacishangmaoyouxiangongsi, weifangyangteshangmaoyouxiangongsi, WeiHongTao123, weijiasle, weiyizhushangmao, wenboyang, WenJiuKeJi, Wen-Reach-Us, WenTimeng, weqfxvznuykilo, wudengbian, Wuhan Jiusheng Building Materials Co., LTD, wuweishichushimeijiadian, XCSIOW, xhrstore, Xiaxue, xinrunhankuokejiyouxiangongsi, xizeyanshangmaoyouxiangongsi, xuqiou, xuyeweisddddd, Y Dream Mall, YAN LI Store, YangYongFuXiaoXuHuan, yantingqin, yanweijuan888, YeXu, Yi XianaA, yimiaoxiangmaoyi, YingHong, Yinuosd, YouYouWoXin, yuan45, Yuanliang1, YuanXinShangYe, yuhuaying002, YunNanBiaoChaoShangMaoYouXianGongSi, YUNYANGSHANGMAO US, yuyandfse, YY store 8-15 days Delivery, ZEBRA_KING, zedikunmingshangmaoyouxiangongsi, ZHANG HAIFENG, zhangpeidejingpinxiaodian, zhangshihan, ZhengYuJieJuDian, ZhiFangShangMao, zhishengning, zhouyao111, ZHUOJUSHANGMAO, ailouwei Store, ajre Store, cockball Store, concerto Store, dmbag01 Store, dressessexy Store, fashionbag_s Store, fashionbag1618 Store, gavingg Store, gysbags Store, honest1ang Store, isupreme Store, junjunlv888 Store, kjlsdasasqws222 Store, kke168_1 Store, lacosk Store, louisfafa777 Store, lufengliu Store, luxurybag098 Store, luxuryperfectbag Store, lvbag6789 Store, magicbag518 Store, magicbag888 Store, makeupbagso Store, messenger_bags Store, newmart365 Store, poplov1854 Store, shelala Store, shuoshuo1202 Store, so_goods Store, stylishhandbagsstore Store, totebagshop_168 Store, vipbagbag666 Store, wh518 Store, ysongbag Store, chunhua98, junyuu-good-goods, keiob77, lishuai23062, luoqipeng5816, pway6868, tan87-70, uklichu66, nora_furslides, CHIBEON, Guanjiaing, marcoutlet.store, wangyuzinf, marcjacobsbagsusshop.com, marcjacobsholiday.com, dooneybourke.shop, marcjacobs-deals.com, qvcusbag.com, clothing50off.com, pandora50off.com, totebag50off.com, jacobssvip.com, jacobsagent.com, jacobstotes.com, jacobshandbag.com, fusanshop.com, marcjacobs-us.shop, marcoutlet.store, themarcjacobs.shop, marcjacobssale.com, marcjacobsale.com, bagmarcjacobs.com, jacobshopping.com, marcjacobsofficialonline.us.com, vsznkm.com, aaliber.com, nordstrom-rackstore.com, marcjacobsn.com and marcjacobsonline.us.com added to case caption.

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to a Certain Defendant

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for entry of default as to Certain Defendants, MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for default judgment as to Certain Defendants

(Exhibit A)

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC 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 Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of Defendant No. 8 39 will be heard at the telephonic hearing set for 9/6/2023 at 9:45 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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 Andrea R. Wood: Telephonic status and motion hearing held on 9/6/2023. Plaintiffs' motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of Defendant No. 8 [39] is granted. Enter Default Judgment Order. Telephonic status hearing set for 9/27/2023 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of 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

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/11/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order[45] in the amount of $500,000 as to certain defendants

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to a Certain Defendant

MINUTE entry before the Honorable Andrea R. Wood: Pursuant to the notice of voluntary dismissal filed 9/18/2023 47, Plaintiff has dismissed its claims against the only remaining Defendant in this case (Maychyhill, No. 8). As all claims as to all Defendants have now been resolved, this case will be closed. Telephonic status hearing set for 9/27/2023 is stricken. Civil case terminated. Mailed notice

NOTICE of withdrawal of Surety Bond 24 by John Summerfield (received for docketing 4/5/2024) (received at the Intake Counter 3/29/2024).

FULL SATISFACTION of Judgment regarding order 45 in the amount of $500,000 as to certain defendants