2023-cv-16400

COMPLAINT filed by Christian Dior Couture, S.A.; Filing fee $ 402, receipt number AILNDC-21379491.

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 John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Christian Dior Couture, S.A. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Christian Dior Couture, S.A. 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

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Exhibit 5 - Parts 1-10 regarding declaration 16

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 11-19 regarding declaration 16

Exhibit 5-11

Exhibit 5-12

Exhibit 5-13

Exhibit 5-14

Exhibit 5-15

Exhibit 5-16

Exhibit 5-17

Exhibit 5-18

(Exhibit 5-19)

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 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

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 [13] is granted. Plaintiff's motions for leave to file under seal [3] and for electronic service of process [19] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 12/4/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $129,000 posted by Christian Dior Couture, S.A. (Document not scanned).

MOTION by Plaintiff Christian Dior Couture, S.A. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for preliminary injunction[25]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Christian Dior Couture, S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/13/2023, answer due 1/3/2024.

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 [25] is taken under advisement. Any objection or response is due before 12/18/23. 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 18, 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 Christian Dior Couture, S.A. regarding order on motion for preliminary injunction, text entry, terminate motions, [28]

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 [25] 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 12/28/23 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 12/18/2023. Mailed notice

NEW PARTIES: Foshan Dylam Trade Co., Ltd., Shanghai La Beaute International Trading Co., Ltd., Yiwu Dangni E-Commerce Firm, Yiwu Leiran Jewelry Co., Ltd., Yiwu Shanglan Jewelry Co., Ltd., Yiwu Xina Jewelry Co., Ltd., Akili Store, Bandai figures Store, CASETIFY BEST Store, Infinite Jewelry Store, JJ Jewelry Store, Kinel Silver 925 Jewelry Store, MarPsc Jewelry Store, MH Trendy Jewelry Store, Or So Store, PEARLs Accessories Material Store, Shop1102691256 Store, Shop1102775286 Store, Shop1102908461 Store, Shop1103150628 Store, SUYU Jewelry Store, Ximu001 Store, A1651X8LGKNYQW, A2LALH9SP2H0U3, A2RUI9FO2Q9ULS, A328EL8Y5HNWQR, A3KDUSPSEWFYI, A3S0F8MKFKEWR6, AA-UNANMU, AcquiesceA, AG67FYKSLY9IZ, ALM2TY2ODDNEA, amaz1ng, amchejuju, anqingjiamengwangluo, ATMCE, AUROLRAN, AWXUESUPER8, BABIBABO, BAOYMStore, Bling-Full, Bluenut, Boutiqueshop222, bssj, BVLVO Jewelry, CCDEGUI, CEMAXINXI, CETVLY, cgvhfdsghdf, ChengDouGangMoHuDianZiShangWuYouXianGongSi, chengduyukuanzhankejiyouxiangongsi, ChengShaoLingxiaodian, Chenxiongshangmao15, Cinlan Jewelry, Clover L4, cServe, cuixinglongdejingpindian, CXIANGQ, DaHuoPu, dangshanxianxiaoxiaolishuiguoxiaoshouyouxiangongsi, Delivery-US, dilaiyushop, dinganbuwenshangmaoyouxiangongsi19416, DouWenHang1, Eristin, EternityTreasures, Fen Yang Shi Si Jia Xian Hua Fang, fengqiuxianjianhongbaihuodian, FlameerUS, foshanshijushanfushangmaoyouxian, fusheng2, GaoChao LvCiShang, chmh, m2xn, thekingofnecklaces, umvh, w0n1, eomp19, flyflower44, hubeishengchaohuans_0, hui861-86, pioneercxx, taiyuanshishiguaishangmaoyouxiangongsi, zhengbin05, luciasupplier5 - alesordi@hotmail.com, lucky_bags3, luochun690, lux.mhtiarne, luxury_alice_bag111, luxury_lv_chanel13, luxury0066, luxuryconcourse1688, luy.ihui, lv_love_bag7, lvhong9, meaneernakend1990, monicazhang2023, nickanna731, ozytbu9d, personalshopper_love2, peter_fashion_1, picknavy63, saliabag, sharoncoomes, shiting_shoes, shuanglingma, tiffany_sneaker, wholesaleshop711, xc_uus, xiaoh3850, xingkong652, xunyu831, yyy369123, luxuryshoes0413, pan18028166651, punishmentsfirmanzl57802, sasigzfhu9w, topluxurybagstores, unboxingthebag, user1037296753061, user4965698191361, user7795578549225, waappsupplier, walnuts0326, xh276081ery, xusheng123123, yasmine.zahran0, KZKRUS and yuanxiao.LLC added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Christian Dior Couture, 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 [32] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 82 is dismissed from this case. Mailed notice

SUMMONS Returned Executed by Christian Dior Couture, 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

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

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.

ATTORNEY Appearance for Defendant AcquiesceA by Travis Jacob Stockman

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), defendant no. 39 is dismissed from the case. Mailed notice

NOTICE of Voluntary Dismissal by Christian Dior Couture, 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 39 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 48, 55, 89, and 129 are dismissed from this case. Mailed notice

ANSWER to Complaint by AcquiesceA

Certificate of Service

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff and defendant AcquiesceA are directed to review the procedures for initial status reports, located at [https://www.ilnd.uscourts.gov/judge-info.aspx?79eF+7uiX7ewBj/ITKrjoA==] and to submit an initial status report by 1/23/2024. The report should include a proposed case management schedule reflecting any disputes between the parties as to the proposed schedule. Mailed notice

NOTICE of Voluntary Dismissal by Christian Dior Couture, 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 43 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant number 1 is dismissed from this case. Mailed notice

STATUS Report Per 42 by Christian Dior Couture, S.A.

MOTION by Plaintiff Christian Dior Couture, S.A. for entry of default, MOTION by Plaintiff Christian Dior Couture, S.A. for default judgment as to all Defendants with the exception of certain Defendants

(Exhibit A)

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for entry of default, motion for default judgment, 46

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

(Exhibit 1)

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 46 is taken under advisement. Any objections or responses are due by 2/9/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 1/31/24. 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 Christian Dior Couture, S.A. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 49

Exhibit A

(Exhibit B)

NOTICE of Voluntary Dismissal by Christian Dior Couture, 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 51 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 128 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 46 is granted as to the remaining defendants, with the exception of Defendants AcquiesceA (Defendant No. 30) and AUROLRAN (Defendant No. 37). Enter default judgment order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 2/9/2024. Mailed notice

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

FULL SATISFACTION of Judgment regarding order[54] in the amount of $150,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 55 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 37 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 56, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants Nos. 41 and 66. Mailed notice

STIPULATION of Dismissal as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr:Upon receipt of the plaintiff's notice of stipulation of dismissal 59 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii), defendant no. 30 is dismissed from this case. This matter is concluded. All deadlines are stricken, and any pending motions are denied as moot. Civil Case Terminated. Mailed notice

full SATISFACTION of Judgment regarding order[54] in the amount of $150,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 61, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant No. 42. Mailed notice

NOTICE of withdrawal of surety bond 24 by John Summerfield. (Received at the Intake Counter on 04/18/24)

FULL SATISFACTION of Judgment regarding order[54] in the amount of $150,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 64, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 54. Mailed notice