2023-cv-16270

COMPLAINT filed by Loewe S.A.; Filing fee $ 402, receipt number AILNDC-21365726.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Loewe S.A. Schedule A regarding complaint[1]

MOTION by Plaintiff Loewe S.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Loewe S.A.

Notice of Claims Involving Trademarks by Loewe S.A.

ATTORNEY Appearance for Plaintiff Loewe S.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Loewe S.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Loewe S.A. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Loewe S.A. by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (Civil Category 2).

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.

MOTION by Plaintiff Loewe S.A. for temporary restraining order Including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Loewe S.A. in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Nicolas Lambert regarding memorandum in support of motion[12]

Exhibit 1

SEALED EXHIBIT by Plaintiff Loewe S.A. Exhibit 2 - Parts 1-6 regarding declaration[14]

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

MEMORANDUM by Loewe S.A. in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 11 is granted. Plaintiff's motions for leave to file under seal 3 and for electronic service of process 16 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 11/29/2023. Mailed notice

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

SURETY BOND in the amount of $109,000 posted by Loewe S.A. (Document not scanned).

MOTION by Plaintiff Loewe S.A. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Loewe S.A. in support of motion for preliminary injunction[22]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Loewe S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/8/2023, answer due 12/29/2023.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [22] is taken under advisement. Any objection or response is due before 12/13/23. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before December 13, 2023. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

CERTIFICATE of Service by Plaintiff Loewe S.A. regarding order on motion for preliminary injunction, text entry, terminate motions, [25]

Exhibit A

Exhibit B

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 [22] 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 12/20/23 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 12/13/2023. Mailed notice

NEW PARTIES: 666 LADY FASHION Store, Adogirl Official Store, Baiyou Haoyidian Store, Beauty Fashion Store, Bordit Living Store, C high quality clothing Store, chuan027 Store, Cyanrose Official Store, DEAR-LIFE Store, Depictdream Official Store, Dream Bird Store, EVLOOKS Store, FMANYUE Store, French fries keychain Store, Global Haute Customization Store, JIAMI Official Store, JILL MILL Official Store, JURO Store, LIOUMO Accessories Store, Lucky Girl Bag Store, Luxury Scarves Store, Maylis Life Store, Momoko High-end Jewelry Store, NICEAWAY Store, Olly House Decoration Store, pamwallymensa Scarf Store, Qiukichonson Store, Saythen Official Store, sejane4131 Store, Shop1100387143 Store, Shop1102280495 Store, Shop1102423658 Store, Shop1102439973 Store, Shop4601027 Store, Shop910641038 Store, Sifreyr Official Store, SunGoods Store, Tresbelle Store, TWINFLAMES Store, Vamos Todos Official Store, Women Mujer Shoes Store, XING WEI SI Sweater Store, XRDS Fashion Shop Store, Yimoer Store, YUZACDWX Store, ZARO Store, ANAA9QTPXLPUD, ANGRJLMPAC4OG, BeautiHome, Chikencall, Diji Electronic Commerce Co., Ltd., jiayedianzishangwu, jiningyiqishangmaoyouxiangongsi, Kyushu Culture, LJSMWQ, qujingjianlidianzishangwuyouxiangongsi, QUREZA, shengqiaodianzishangwufuwubu, sunshinejing, Tinco US Shop, wenxiaoqin-001, YISEN's shop, zelongdujiqu, zhang si jin, zhangxiaolinbeimei, zhijiangshichuxiangwangluokejiyouxiangongsi, aimei888 Store, bagscoolsite Store, bagshop1868 Store, chh1010 Store, dhgatesing Store, fashionalno3 Store, fashionshop889 Store, health_lifes Store, hiq1213, iknowu Store, jjjunesoy Store, luxuryhbag Store, LUXURYSUNGLASSES Store, offsstore, panfushi888 Store, supreme99 Store, winterdownparka2019, zzblunt Store, lipta0, usa.factory, alanhoo8866, anilabreenda, luxury_bags_fromchina, shenda888, Truth and source shoes, bag2109, catierolex, JUSTUP, dickyluxurybags.com, foryourbags.com, discountloewe.com, loewebaguk.com, loeweoutlet.shop, loewesshop.com, loewedeals.com, loeweromania.com, loeweportugal.com, loeweindia.com, loewe-dubai.com, baratoloewe.com, loewebagsaleusa.com, replicasmall.com and loewefactoryoutlet.com added to case caption.

NOTICE of Voluntary Dismissal by Loewe S.A. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 29 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 50 and 79 are dismissed from this case. Mailed notice

SUMMONS Returned Executed by Loewe S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/27/2023, answer due 1/17/2024.

Declaration of Quinn B. Guillermo

Exhibit A

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice.

NOTICE of Voluntary Dismissal by Loewe S.A. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 33 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 37 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Loewe S.A. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 35 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 3, 59, and 91 are dismissed from this case. Mailed notice

MOTION by Plaintiff Loewe S.A. for entry of default, MOTION by Plaintiff Loewe S.A. for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by Loewe S.A. in support of motion for entry of default, motion for default judgment[37]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[38]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [37] is taken under advisement. Any objections or responses are due by 2/5/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 1/26/24. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Loewe S.A. regarding order on motion for entry of default, order on motion for default judgment, text entry, [40]

Exhibit A

Exhibit B

NOTICE of Voluntary Dismissal by Loewe S.A. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 42 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 8 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 37 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Ordere Signed by the Honorable John J. Tharp, Jr on 2/6/2024. Mailed notice

NOTICE of withdrawal of Surety Bond 21 by John Summerfield (received at the Intake Counter 4/18/2024).

MOTION by Plaintiff Loewe S.A. for entry of default, MOTION by Plaintiff Loewe S.A. for default judgment as to Defendant dickyluxurybags.com

Exhibit A

MEMORANDUM by Loewe S.A. in support of motion for entry of default, motion for default judgment[47]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment against defendant no. 95 47 is taken under advisement. Any objections or responses are due by 5/10/2024. The plaintiff is directed to provide defendant no. 95 with notice of the default proceedings against it by 5/2/2024. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendant by third parties (or otherwise obtained by the plaintiff) informing it of the default proceedings against it and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Loewe S.A. per 50

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant no. 95 not having objected, the plaintiff's motion for default judgment against that defendant 47 is granted. Enter default judgment order. Civil case terminated.Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 5/14/2024. Mailed notice