2023-cv-16379

COMPLAINT filed by Christian Dior Couture, S.A.; Filing fee $ 402, receipt number AILNDC-21377102.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Schedule A regarding complaint 1

MOTION by Plaintiff Christian Dior Couture, S.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Christian Dior Couture, S.A.

Notice of Claims Involving Trademarks by Christian Dior Couture, S.A.

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Maria Valdez. 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 Christian Dior Couture, 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 Christian Dior Couture, 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

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Exhibit 5 - Parts 1-10 regarding declaration 14

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

Exhibit 5-5

Exhibit 5-6

Exhibit 5-7

Exhibit 5-8

Exhibit 5-9

(Exhibit 5-10)

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Exhibit 5 - Parts 11-15 regarding declaration 14

Exhibit 5-11

Exhibit 5-12

Exhibit 5-13

Exhibit 5-14

(Exhibit 5-15)

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

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for miscellaneous relief 17

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

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 17, motion for temporary restraining order 11, motion for leave to file 3 before Honorable Elaine E. Bucklo on 12/6/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Motion for leave to file under seal [3] is granted. Motion for electronic service of process [17] is granted. Motion for a temporary restraining order [11] is granted. Enter Order. Motion hearing set for 12/6/2023 is stricken. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 12/5/2023.

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

MINUTE entry before the Honorable Elaine E. Bucklo: Because the temporary restraining order will expire on 12/19/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 12/15/2023. Greer, Burns & Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 1/19/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 1/12/2024 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Christian Dior Couture, S.A. (Document not scanned)

MOTION by Plaintiff Christian Dior Couture, S.A. for preliminary injunction

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for preliminary injunction[26]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[26] before Honorable Elaine E. Bucklo on 12/20/2023 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Christian Dior Couture, S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/15/2023, answer due 1/5/2024.

Declaration of Quinn B. Guillermo

Exhibit A

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations Identified on Schedule A by Michael P. Adams Defendant WDIRARA

MOTION by Plaintiff Christian Dior Couture, S.A. for Entry of an Asset Restraint Order as to Defendant No. 59 Agreed

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[31] before Honorable Elaine E. Bucklo on 12/27/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction [26] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Exhibit 5 to the Declaration of Nicolas Lambert [15-16] and the TRO [22]. Agreed motion for entry of asset restraint order as to Defendant No. 59 [31] is granted. Enter Agreed Asset Restraint Order as to as to Defendant No. 59. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 12/20/2023. Mailed notice.

AGREED ASSET RESTRAINT Order as to Defendant No. 59 signed by the Honorable Elaine E. Bucklo on 12/20/2023. Mailed notice.

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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 Christian Dior Couture, S.A. as to certain defendants

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to Certain Defendants

MOTION by Plaintiff Christian Dior Couture, S.A. for entry of default as to Certain Defendants, MOTION by Plaintiff Christian Dior Couture, S.A. for default judgment as to Certain Defendants

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. 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 Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [39] before Honorable Elaine E. Bucklo on 1/12/2024 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment against the defendants identified on Schedule "A," with the exception of defendant Nos. 7, 9, 29, AND 59 [39] is granted. Enter Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Christian Dior Couture, S.A., or its counsel, Greer, Burns & Crain, Ltd. Status hearing to stand as to remaining non-dismissed defendant. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 1/11/2024. Mailed notice.

STATUS Report per 24 by Christian Dior Couture, S.A.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff report there's active settlement negotiations with remaining defendants. Plaintiff will move for default judgment at a later date where appropriate, the status hearing is reset for 2/15/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 2/8/2024. The court will enter an order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to certain defendants

FULL SATISFACTION of Judgment regarding order 44 in the amount of $250,000 as to certain defendant

STATUS Report Pursuant to 46 by Christian Dior Couture, S.A.

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the plaintiff's status report, parties report they are having settlement discussions with remaining defendant no. 59. Status hearing is reset for 3/28/2024 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 3/21/2024. The court will enter a scheduling order in response to the status report. If a stipulation to dismiss is submitted in advance of that date, the hearing will be stricken. Mailed notice.

FULL SATISFACTION of Judgment regarding order 44 in the amount of $250,000 as to certain defendant

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to certain defendant

STATUS Report Pursuant to 50 (Joint) by Christian Dior Couture, S.A.

MINUTE entry before the Honorable Elaine E. Bucklo: A notice of dismissal has been filed. This case is dismissed with prejudice pursuant to FRCP 41(a)(1) as to remaining defendant. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

NOTICE of withdrawal of bond 25 by John Summerfield. (Attachment) (Received at the Intake Counter on 03/29/2024)