2024-cv-00793

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-21583524.

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 John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 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[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 1-7 regarding declaration[16]

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

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 18 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining order Signed by the Honorable John J. Tharp, Jr on 2/2/2024. 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 $ 90,000 posted by Chrome Hearts LLC. (Document not Imaged)

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[24]

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 2/12/2024, answer due 3/4/2024.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 24 is taken under advisement. Any objection or response is due before 2/16/24. 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 February 16, 2024. 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 Chrome Hearts LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 27

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 24 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 2/23/24 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 2/16/2024. Mailed notice

NEW PARTIES: Bengbu Jiahuimei International Trading Co., Ltd., Dongguan Queenail Cosmetics Co., Ltd., Foshan Huaji Baobei Nail Products Co., Ltd., Guangzhou Haohao Nail Products Co., Ltd., Guangzhou Jinghuan Trading Co.,Ltd., Guangzhou Leidankou Cosmetics Co., Ltd., Guangzhou Merry Technology Co., Ltd., Guangzhou Yongyang Handicraft Co., Ltd., Jiangxi Fangxia Import And Export Trading Co., Ltd., Jinhua Wennaier Trading Co., Ltd., Longkou Ronghao International Co., Ltd., Mingyang (guangzhou) Technology Co., Ltd., Nuomisen (guangzhou) Cosmetics Co., Ltd., Qingdao Huiqian Eyelash Cosmetics Co., Ltd., Quzhou Qiying Import And Export Co., Ltd., Shenzhen Hidida Technology Co. Ltd, Shenzhen Sixia E-Commerce Co., Ltd., Yiwu Huanyin Crafts Factory, Yiwu Huanyin Trade Firm, Yiwu Jiaxi Art Co., Ltd., Yiwu Kunya Trade Co., Ltd., Yiwu Mengzhong Household Products Co., Ltd., Yiwu Nuojin Trading Co., Ltd., Yiwu Taoxin Import And Export Co., Ltd., Yiwu Xinyun Jewelry Co., Ltd., A2ZH1LVBUIIP9A, A4RLYBJBA6QDO, AR1PWUZ84VIG, Auzztty, Beginow store, BJQZX, BLNAI, brandPAURO, Carina shop, CBDx, Chrome Accessories for iPhone, Chuangguang Boutique, ConoBala-US, CRMCC, CYW-yulben, DAMAI STORE, DHWssdmkldsio3, dohaanhhamw33, EVBAGLU, Ftrade, Goblin Love, Guangzhou Leng Zhang trading Co., LTD, hefeimairuowangluokejiyouxiangongsi, hongtung984, Imsohot Beauty, JINZHOUFZ, Joyingshop, kangpengyan youth, kunmingbikuayuanshangmao, Kvasira Anh, MagicShoop, Magrace store, SHUOSKY, SISTER STORE, Street Region, Taga e-commerce Studio -US, Tessio, THAM NGHIA Store, ThanhStore0808, VIETHOANG STORE56, Waitsoul-Jewelry, WhyNotNailIt, xiangyangshijiayichengshangmaoyouxiangongsi, XIAOKAIBHD, yahuizhou, YangCiZi, ZLYY, pa07105, pengshuqin88, gtpk11, mray3151, shkdjcy, Anwaqiao jewelry, Fingertip craft wearing, Gaea nail beauty, kingfairy, Lanhai ornaments, NICE SUNDAY, Radiant Gems, Rimberio Jewelry, Waoh nails shop, WWENJIANAILS, Yinhange jewelry factory, Yueyue bags and Leweihang added to case caption. (Text entry; no document attached.)

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 31 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 56 and 90 are dismissed from this case.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

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), defendants nos. 30, 37, 51, 52, 59, 72, and 81 are dismissed from this case. Mailed notice

ATTORNEY Appearance for Defendant Ftrade by Adam Edward Urbanczyk

MOTION by Defendant Ftrade for extension of time UNOPPOSED

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [34] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 84 and 85 are dismissed from this case Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Ftrade's unopposed motion for extension of time [37] is granted. The deadline for it to answer or otherwise respond to the complaint is extended to 3/29/24. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [40] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), the defendants listed therein are dismissed from this case. Mailed notice

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 3/21/2024, answer due 4/11/2024.

Declaration of Trevor C. Talhami

Exhibit A

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), defendants nos. 23 and 61 are dismissed from this case.Mailed notice

ATTORNEY Appearance for Defendant Yiwu Mengzhong Household Products Co., Ltd. by Christopher Paul Keleher

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [46] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 46 is dismissed from this case. Mailed notice

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[48]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[49]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [48] is taken under advisement. Any objections or responses are due by 4/29/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 4/17/24. 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 Chrome Hearts LLC regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, [51]

Exhibit A

Exhibit B

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [53] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 35 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 [48] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 4/30/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order[56] in the amount of $125,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [57], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 22. Mailed notice

FULL SATISFACTION of Judgment regarding order[56] in the amount of $125,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [59], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants nos. 5, 8, and 25. Mailed notice

FULL SATISFACTION of Judgment regarding order[56] in the amount of $125,000 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. 2. Mailed notice

FULL SATISFACTION of Judgment regarding order[56] in the amount of $125,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[56] in the amount of $125,000 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 L.R. 58.1, enters the satisfaction of judgment as to defendant no. 88. Mailed notice