2023-cv-13820

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 402, receipt number AILNDC-21096160.

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

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's motion for leave to file under seal [3] is granted. Mailed notice.

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[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Mario Lejtman regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1-7 regarding declaration[15]

MOTION by Plaintiff Chrome Hearts LLCfor 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[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's motion for temporary restraining order [12] and motion for electronic service of process [17] are granted. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Thomas M. Durkin on 9/22/2023. Mailed notice.

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

SURETY BOND in the amount of $141,000 posted by Chrome Hearts LLC (Document not scanned.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

Trademarks

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

MOTION by Plaintiff Chrome Hearts LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Chrome Hearts LLC in support of extension of time[25]

Declaration of Rachel S. Miller

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff's motion to extend the temporary restraining order through and until October 20, 2023 25 is granted. Mailed notice.

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

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

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[30]

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 10/17/2023, answer due 11/7/2023.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable Thomas M. Durkin: Telephone motion hearing set for 10/20/2023 at 9:15 a.m. as to Plaintiff's motion for preliminary injunction [30]. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Members of the public and media will be able to call in to listen to this hearing. 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 Chrome Hearts LLC as to certain defendants

MINUTE entry before the Honorable Thomas M. Durkin: Telephone motion hearing held on 10/20/2023. For the reasons stated on the record, Plaintiff's motion for preliminary injunction [30] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 11/20/2023 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 10/20/2023. Mailed notice.

NEW PARTIES: Anhui Yifeng Mesh Co., Ltd., Dongguan Byoung Beauty Cosmetics Technology Co., Ltd., Dongyang Bo Yue Nails Trade Co., Ltd., Guangzhou Kinnco Beauty Cosmetics Co., Ltd., Guangzhou Liaoyuan International Trade Co., Ltd., Guangzhou Oyasy Nail Products Co., Ltd., Guangzhou Qiancai E-Commerce Co., Ltd., Guangzhou Xinfeng Commerce And Trade Co., Ltd., Guangzhou Yoya Arts & Crafts Co., Ltd., Hangzhou Linghe Trading Co., Ltd., Hangzhou Zhishangfei Biotechnology Co., Ltd., Huzhou Jianaier International Trade Co., Ltd., Jiangxi Qianya Cosmetics Co., Ltd., Nanchang Smelling Time Industrial Trade Co., Ltd., Ningbo Bomei Packing Co., Ltd., Ningbo Sundy IMP & EXP CO.,Ltd, Shenzhen Egirl Trading Co., Ltd., Shenzhen Hui Zhi Rong Technology Co., Ltd., Shenzhen Longqing Technology Co., Ltd., Shenzhen Toyoung Beauty Technology Co., Ltd., Yantai Beauty Top Electronic Commerce Co., Ltd., Yiwu Baiyan Cosmetic Tool Co., Ltd., Yiwu City Weiqi Trading Co., Ltd., Yiwu Dehang Cosmetics Co., Ltd., Yiwu Gemei Cosmetics Co., Ltd., Yiwu Greencotton Daily Necessities Co., Ltd., Yiwu Huni Electronic Commerce Co., Ltd., Yiwu Jiaxiu Import And Export Co., Ltd., Yiwu Jiazan E-Commerce Firm, Yiwu Lanfan Trade Co., Ltd., Yiwu Runni Art Co., Ltd., Yiwu SC Stainless Steel Products Co., Ltd, Yiwu Weiju Import And Export Co., Ltd., Yiwu Weiqi E-Commerce Firm, Yiwu Yiliang Trading Co., Ltd., Daisy01 Store, Fashion Silver Jewelry Wholesale Store, Fishsheep Handcaraft Store, GISLAN Makeup Store, INX Nail Art Store, Nail-Nila Store, A1YTXYEBQN7ZIJ, changhaitao youth, DAMENGMEI, DOTTI VEN, duohewangluokejiyouxiangongsi, ENDAGALIFAJIAN, enshishihuanchashangmao, GeQianXiaoDian, Gifiky, Hanako_Store, hengpengwangluokejiyouxiangongsi, Hkanlre, jingjiangshixingshengriyongbaihuoshanghang, Kamize, KP Lucky, LecomentStrore(7-15D Delivery), liangpieyinabaihuodian, Marsrut TM, Namchil, nastiastore, OUPING HOME DECOR, Pawkuchen, Ppgod, qu le, rsyturtf, runk, Study Kitchen, Sun&Beam, SW Inc, SYQOIU, taolinnn, Teronson, TUXMAXTH02, Uhada, Vanesseva, VRINDAVRIHAS, Wikatiania, xianfudujiqu, XINniran, XinxindingDian-US, yamaxunzhanghaobaihuo, yangbangbaihuo, Yuoos, zengqigaibaihuo, ZENITH FASHION, Zhong Yangshan-US, Zofo store-US, fashinshoes__store, 20370910967, CWAYY BEAUTY, Eternal Fashion Jewelry, Fairy fair, Fashion Nail, Flower baby Manicure, Fruit Fingertip Art, Glamour Crossing, Hola Beauty, HT Phone case, JW Handmade Studio, lilishan, LWCEME, Medusa nail, MINGTAISHIPIN, MOILY SHOPPING BOUTIQUE, Mona handmade, Mona Nails, Nail Polish, Nail Pro, OB JEWELRY MFG, Pretty Rose, Rose nail, Sister Beauty nail salon, Small by the sea, Starry Handmade Nails, Tianmi jewelry, TrendCollectibles, TrendyU, Xinyue manicure, YKHMYB, zhengzhixuan, Cuke, E-STYLE and FCOGIN added to case caption.

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 10/27/2023, answer due 11/17/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

ATTORNEY Appearance for Defendants Marsrut TM, Study Kitchen by Nicholas S. Lee

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

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

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

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 11/20/2023 and continued to 1/4/2024 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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 issue 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 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[45]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[46]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 1/4/2024 is stricken. A telephone hearing as to the motion for entry of default, motion for default judgment 45 is set for 12/7/2023 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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 issue 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 Thomas M. Durkin: Motion hearing held on 12/7/2023. No one appeared on behalf of defendants. Motion for entry of default and for default judgment [45] is granted. Plaintiff's counsel is to send an updated proposed default judgment order to Judge Durkin's proposed order inbox. Civil case terminated. Mailed notice.

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

FINAL Default Judgment Order. Signed by the Honorable Thomas M. Durkin on 12/7/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendants

SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant