2023-cv-05187

COMPLAINT filed by Celine SA; Filing fee $ 402, receipt number AILNDC-20904495.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Celine SA Schedule A regarding complaint[1]

MOTION by Plaintiff Celine SA for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Celine SA

Notice of Claims Involving Trademarks by Celine SA

ATTORNEY Appearance for Plaintiff Celine SA by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Celine SA by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Celine SA by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Celine SA by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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 Celine SA for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Celine SA 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 Nicolas Lambert regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Celine SA Exhibit 2 - Parts 1-8 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

(Exhibit 2-8)

MOTION by Plaintiff Celine SA for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Celine SA in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for temporary restraining order 13, motion for miscellaneous relief 18 before Honorable Manish S. Shah on 8/15/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [13] [18] are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 8/14/2023. Notices mailed.

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

SURETY BOND in the amount of $ 50,000.00 posted by Celine SA. (Document not imaged)

MOTION by Plaintiff Celine SA for extension of time of Temporary Restraining Order

MEMORANDUM by Celine SA in support of extension of time[25]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[25] before Honorable Manish S. Shah on 8/24/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 25 is granted, and no appearance on the motion is necessary. The TRO is extended to 9/11/23. Notices mailed.

MOTION by Plaintiff Celine SA for preliminary injunction

Exhibit A

MEMORANDUM by Celine SA 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 Manish S. Shah on 9/7/2023 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Celine SA as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/1/2023, answer due 9/22/2023.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Manish S. Shah:Motion hearing held on 9/7/23. For the reason stated on the record, Plaintiff's motion for entry of a preliminary injunction 29 is granted. Enter order.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Manish S. Shah on 9/7/2023.

NOTICE of Voluntary Dismissal by Celine SA as to certain defendants

NEW PARTIES: MISSFU, MoYoTo, nanjingxingermaoyiyouxiangongsi, NUANkong, OUREETT, Prara, putianshimeizhoudaoshangdezongdubaihuodian, qiaokoufeiyu, qihangle, qingyunqunying, Qinyongd-ML, qiuchunhua9192, qiyuemiaobaihuodian, QTWM, Remix US, RieyDiof, rongkepolo, Ruiersd, rundicn, Sanfengstore, sanyashiyuzhengqingshangmaoyouxiangongsi, Saxony, shan xi he long neng yuan ke ji you xian gong si, Shangpin Shopping Mall, shanxizhongxinhuawangluokejiyouxiangongsi, shengshengdeshangdian, ShenzhenCity Jiachuang Jewelry Co., Ltd, SHIXIAOMIN, shunchangdajiancanyouxianzerengongsi, SL45, songboor, SQSCXYTHSXCS, SRAGTKR, suininghaozhongbaihuodian, SuperEasyy, suwfnksf, SUWIKIOK, TaFeiYanMaoYi, TIANQIMAOYI, Tienda Heafell, TigerOVO, tigerys, tuuodianzishangwuyouxiangongsi, twbyhqzgsmd, uiuiooop, US-24G, US-JKYDD, WangQiYouXianGongSi, wangtianhao, wangzijian.us1, WBF STORE, weifangzhabuwangluokejiyouxiangongsi, weijun store, weimengqi, weiyouliang, wenbo dianpu, wenqiudedianpu, wuwenyuan, wuyuchebfghgf, Wuyun Store, WXYBCBD, XIANHONG-XILU, xiaobinghgh, xiaobu-shop, xiaoliangbaihuodian, xiegengguo, XQLBMBD, xuadhai, yangaogg, yangjiayuo, yangsuoxiansubangbaihuodian, yangyuchendw, YANHUISHOP, YiHengYangMaoYi, YilinTechnology 7-12 Days, yjpstore-us, YLXIN shop, youxiangongsi-AMZ, Yybobo, ZhaiChengHuiUS, zhengwei7969, zhengzhouqiuxiangshangmaoyouxiangonsi, zhilongjj528, ZhongHongWangLuoKeJi, zhuzhoushiqiuxishangmaoyouxiangongsi, zitian147258963, ZJWENBMBD, zllzllymx, zzjdd, brand1314, cnosme, das881 Store, gbeltsunglasses, Good faith seller 888, jinduoduo Store, jx135920 Store, Luxury Sunglasses, mice86 Store, Mt_leather, overallss Store, portgas_d_ace Store, qifei07, qifei2022, qiye005, sevenweek Store, ssllhyll168 Store, ten8888, vv_tees Store, wertyu77, womenluxury Store, ak1158, cakemo_99, duxiaochuanjjj, hefeimoucuanshan-0, iangyoujuasdasd, kuaile056, lego_w, linlin03, quzh_4882, taoshengyijiu3, xilyforve, yabu1668, 28.12928906, alai.a2023, breeze7289, chenxiaochu11, dnckeldsen, first_brand_factory7, genesis___hang, joey00712, julissa17884, ling1838070, luxury_brand_studio69, tina22luxury, yan95911, luxurybagschinacc1, Huaxnn, Seejeer, 711luxury.com and limimg01167 added to case caption.

NOTICE of Voluntary Dismissal by Celine SA as to certain defendant

NOTICE of Voluntary Dismissal by Celine SA as to certain defendants

NOTICE of Voluntary Dismissal by Celine SA as to a Certain Defendant

MOTION by Plaintiff Celine SA for entry of default as to Certain Defendants, MOTION by Plaintiff Celine SA for default judgment as to Certain Defendants

(Exhibit A)

MEMORANDUM motion for entry of default, motion for default judgment 39 by Celine SA

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum 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 Manish S. Shah on 10/26/2023 at 09:45 AM.

(Exhibit A)

NOTICE of Voluntary Dismissal by Celine SA as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 39 is granted. Enter Default Judgment Order. Plaintiff shall file a status report on settlement as to the remaining defendants or notice of voluntary dismissal by 11/15/23. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 10/26/2023. Notices mailed.

NOTICE of Voluntary Dismissal by Celine SA as to certain defendants

FULL SATISFACTION of Judgment regarding order 45 in the amount of $50,000 as to certain defendant

ATTORNEY Appearance for Plaintiff Celine SA by Quinn Bradley Guillermo

STATUS Report per [44] by Celine SA

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Civil case terminated. Notices mailed.

FULL SATISFACTION of Judgment regarding order 45 in the amount of $50,000 as to certain defendant

NOTICE of withdrawal of bond 24 by John Summerfield. (Document received for docketing on 3/1/24)