2024-cv-00288

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-21514430.

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 Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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

(List of Trademarks ex 1)

((List of Trademarks ex 2))

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

MOTION by Plaintiff Chrome Hearts LLC for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Chrome Hearts LLC 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 Mario Lejtman regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1 - 6 regarding declaration 16

Exhibit 5-1

Exhibit 5-2

Exhibit 5-3

Exhibit 5-4

Exhibit 5-5

(Exhibit 5-6)

MOTION by Plaintiff Chrome Hearts LLC for 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 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 miscellaneous relief 18, motion for leave to file 3, motion for temporary restraining order 13 before Honorable Elaine E. Bucklo on 1/23/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal [3]; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, temporary transfer of the domain names, a temporary asset restraint and expedited discovery [13]; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 2/6/2024, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 1/30/2024. Law Firm Greer, Burns and 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 3/7/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 2/29/2024 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.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Elaine E. Bucklo on 1/23/2024. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Chrome Hearts LLC (Document not scanned.)

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

NOTICE of Motion by Rachel S Miller for presentment of extension of time[25] before Honorable Elaine E. Bucklo on 2/2/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's ex parte motion to extend the temporary restraining order 25 is granted to 2/20/2024. Mailed notice.

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

SUMMONS Issued as to Defendant The Partnerships and all other Defendants identified in the Complaint (jcc,) (Text entry; no document attached.)

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

SUMMONS Issued as to Defendant The Partnerships and all other Defendants identified in the Complaint (jcc,) (Text entry; no document attached.)

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction 31

Declaration of Rachel S. Miller

(Exhibit 1)

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction 31 before Honorable Elaine E. Bucklo on 2/21/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/14/2024, answer due 3/6/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for preliminary injunction [31] 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 Doug Anderson [17] and the TRO [23]. Mailed notice.

AMENDED MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for preliminary injunction [31] 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 Mario Lejtman [17] and the TRO [23]. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Elaine E. Bucklo on 2/21/2024. Mailed notice.

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

NEW PARTIES: Luxury-brand-Mokey002 Store, Nail Art Syndrome Store, Shop1102373035 Store, Shop5634013 Store, The only Store, TOMY Keyboard Store, XJMIGO Store, XXXHALU Store, A1A3N732MR73GO, A2AL6WF2HY5XDB, A2D973XF12C68H, A3BV4964204TK, A3Q60V3RA6OQYD, AIFNIY-US, anqingshijianshangmaoyouxiangongsi, chunwangll919, Cool-Hearts, CROWN LOVE LIMITED, cxzkjnlkjfsaqfwtrewqe, DALUSHOP, danzhouqidushangmaoyouxiangongsi., Delivery 7-15 Days, DIY Ornaments US Store, DuiHuoShangMaoYouXianGongSi, fuzhouqiyuanwangluokejiyouxiangongsi, FUZHOUSHISANLIUWANGLUOKEJIYOUXIANGONGSI, gmhbus, HENGYANGRUINUO, HOKMAH MART, huiyuechengmaoyiyouxiangongsi, Li manman, LIGHT RAIN, liuquanweidedian, MA8QP13U9L, MakabakaQQ, maxVLT, MHxin--US, Mlovg, OTEEGX, Seeyoul, ShenZhen Shi AiLiLian E-Business Co.,Ltd, sichuanmingxianhaozekejiyouxiangongsi, susongxianxiaoshenbaihuoshanghang, tianjinshibinhaixinquzixidianzishangwuwangdian, weifangyangxiaoxiaoshangmaoyouxiangongsi, Whimsy Wares Picks, wilti, WUZUJUE, xiangyangshianshukejiyouxiangongsi, youlandianzishangwu, ZhiJiangShiBuBiShangMaoYouXianGongSi, dazzingjewelry, hunian, palme11 Store, st_warehouse Store, aqk2_44, dulqq28, fashionfastlane, fingland382, foshanshinahaiqutaiyue_0, gopduan239, haikoukaigoutengwang_0, linjunhui9, nchan_10, ozhan-73, ruofumaoyi, schaefer82_8, veryselection, wangmeiqi, zhaosonghong, Aaaoo, Affordable Luxury Nails, Coco Park, Colorful life cosmetics yy, FuKang Jewelry, Jade is leather., Mabel Nail Charms, NAIL SPA, PENGJIACHUN, RadiantOrnaments, Trinket of loyalty, fodope.com, chromeheartsclothing.store and chromeheartsclothing.ltd added to case caption. (Text entry; no document attached.)

STATUS Report Per 22 by Chrome Hearts LLC

(Exhibit A)

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

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. Pending defendant(s) responsive pleading, Plaintiff will move for default judgment against remaining defendant(s). Status hearing is reset for 4/8/2024 at 9:45 a.m. (to track the case only; no appearance is required). Status report is due 4/1/2024. The court will enter an order based on the report. Mailed notice.

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

STATUS Report pursuant to 41 by Chrome Hearts LLC

(Exhibit A)

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to a certain Defendant

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)

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment 45 before Honorable Elaine E. Bucklo on 4/10/2024 at 09:45 AM.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff's motion for entry of default and default judgment 45 against all Defendants remaining in this case is granted. Enter Final 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 Plaintiff or its counsel, Greer Burns & Crain, Ltd. Status hearing is reset for 5/21/2024 at 9:45 a.m. as to non-dismissed defendants. (to track the case only, no appearance is required). The parties shall file a joint status report by 5/14/2024 and the court will enter an appropriate order. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 4/11/2024. Mailed notice.

STATUS Report pursuant to 49 by Chrome Hearts LLC

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report 54, Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[50] in the amount of $100,000 as to certain defendant