2023-cv-05032

COMPLAINT filed by Kendra Scott, LLC; Filing fee $ 402, receipt number AILNDC-20885456.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Kendra Scott, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kendra Scott, LLC

Notice of Claims Involving Trademarks by Kendra Scott, LLC

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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 Kendra Scott, LLC for temporary restraining order Including a Temporary Injunction, Temporary Transfer of the Domain Names, Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Kendra Scott, 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 Adrienne T. Montes regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Exhibit 3 - Parts 1-5 regarding declaration[16]

MOTION by Plaintiff Kendra Scott, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Kendra Scott, 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 John J. Tharp, Jr:Plaintiff's ex parte motion for TRO 13 is denied without prejudice. Upon examination of the asserted trademarks, it appears that several are registered to an individual or entity other than the plaintiff. The plaintiff therefore does not have standing to assert those claims. The plaintiff is given leave to amend its complaint and refile a motion for temporary restraining order to narrow its claims to infringements on trademarks that it actually owns, or, alternatively, to allege facts sufficient to show that it is in fact the owner of all the asserted trademarks. Mailed notice

MOTION by Plaintiff Kendra Scott, LLC for reconsideration regarding order on motion for temporary restraining order, text entry, terminate motions, [21]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion to reconsider denial of the motion for TRO 22 is granted. In light of the clarification in the motion, the Court reinstates the plaintiff's motion for temporary restraining order 13. And on the grounds set forth in the motion, plaintiff's ex parte motion for TRO 13 is granted. Plaintiff's motions for leave to file under seal 3 and for electronic service of process 18 are granted. Enter temporary restraining order Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 8/11/2023. Mailed notice

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

SURETY BOND in the amount of $ 105,000.00 posted by Kendra Scott, LLC. (Document not imaged)

MOTION by Plaintiff Kendra Scott, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Kendra Scott, LLC in support of motion for preliminary injunction[26]

Declaration of Rachel S. Miller

Exhibit 1

SUMMONS Returned Executed by Kendra Scott, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/22/2023, answer due 9/12/2023.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [26] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 8/31/23 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 8/23/2023. Mailed notice

NEW PARTIES: kendrafashion.com, kendraonlinefashion.com, kendraonlineshop.com, kendraoutletshop.com, kendrascctjewelers.com, kendrascctjewelry.com, kendrascctjewels.com, kendrasccttfashion.com, kendrasccttjeweliry.com, kendrasccttonline.com, kendrasccttsjeweler.com, kendra-scott-shop.com, kendrasctonlineshop.com, kenrscojewelry.com, ajewelrynecklaceshop.com, ajewerryringshop.com, ajewerryshop.com, artjewelrysales.com, asmaintainsasre.com, awmsmall.com, beenbijoushop.com, bijoushopcenter.com, bijoushopcode.com, bijoushopdigital.com, bijoushopfashion.com, bijoushopglobal.com, bijoushophotel.com, bijoushopland.com, bijoushopsonline.com, bijoushopstudio.com, bijoushopunited.com, buybijoushop.com, buyjewelsshop.com, bybijoushop.com, cbhlstores.com, ckbijoushop.com, clickjewerry.com, cloudjewerry.com, considershops.com, dealcoves.com, educationbijoushop.com, eghvshopus.com, fashaionjewerry.com, findbijoushop.com, firstbijoushop.com, forpiercesforre.com, foxgemshop.com, greatbijoushop.com, indeserttop.com, injewerry.com, injewerryshop.com, insightfulmalls.com, jewelrfashioon.com, jewelrylovefashiongift.com, jewelrylovegiftshop.com, jewelrylovegiftshopy.com, jewelrylovetrendgifts.com, jewelryoutletbiz.com, jewelryoutletinfo.com, jewelryoutletsbase.com, jewelryoutletschoice.com, jewelryoutletsdeal.com, jewelryoutletshot.com, jewelryoutletsown.com, jewelryoutletssales.com, jewelryschic.com, jewelrysdazzles.com, jewelrysmoment.com, jewelrysummerbeststore.com, jewelrysummershopify.com, jewelryswink.com, jewelryvogueshot.com, jewelryvoguessales.com, jewelsshopfun.com, jewelsshopletter.com, jewelsshopsocial.com, jewelstales.com, jewerryart.com, jewerrymedia.com, jewerryonline.com, jewerryshopblog.com, jewerryshopweb.com, kingbijoushop.com, ksjewelsr.online, morejewelsshop.com, myjewerry.com, netjewerryshop.com, newbijoushop.com, onlinerealtimestop.com, onlinesglassesstales.com, otherjewerry.com, phxkrings.com, protojewerry.com, salesfashionjewelrisvip.com, shopdistributedmall.com, shopkendrafashion.com, shopthundermall.com, starbijoushop.com, statebijoushop.com, stylishfashionjewelryshop.com, summerbeautyshoppy.com, thejewerry.com, topierceonline.com, toronmall.com and usabijoushop.com added to case caption.

MOTION by Plaintiff Kendra Scott, LLC for entry of default as to all Defendants, MOTION by Plaintiff Kendra Scott, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Kendra Scott, LLC in support of motion for entry of default, motion for default judgment[31]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[32]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 31 is taken under advisement. Any objections or responses are due by 9/25/23. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 31 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/26/2023. Mailed notice

NOTICE of Removal Material from the Custody of the Clerk's Office by Justin R. Gaudio of the firm Greer, Burns & Crain, Ltd. by the Plaintiff regarding Bond 25.