2024-cv-11910

COMPLAINT filed by PRL USA Holdings, Inc., Ralph Lauren Corporation; Filing fee $ 405, receipt number AILNDC-22747235.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Schedule A regarding complaint[1]

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by PRL USA Holdings, Inc., Ralph Lauren Corporation

Notice of Claims Involving Trademarks by PRL USA Holdings, Inc., Ralph Lauren Corporation

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Marcella Deshonda Slay

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2).

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

BOND in the amount of $ 58,000 check, Receipt No. 100013833. posted by PRL USA Holdings, Inc.

NEW PARTIES: Dongguan Shengen Clothing Co., Ltd., Haikou Meilan Dilaiya Clothing Store (individual Business), Hangzhou Zhongjian Clothing Co., Ltd., Puyang Zhongzhi luggage shop, Suzhou Inter-Trend Trading Co., Ltd., Kim K's Fashion Collection, wen08805, aini666123, aiofghaio2, aiogfba2, aiohfuia2, bushihenpiande, casaqpaida-9662, daihuad_10, eponapartn0, eva6889, fengzhongyuzuodeyun, gaiobgnag55d, gcwsamr, grace_lincoln, hhhh45, hih669, HISS-MOTOR, hokilji, huangfanggg, jial1898, kcbbs_52268, keenekenne2003, linxiaodong1989, liufangliufang, majunqiang, owhehdd-76, pengzhangdale, qingxin wang, r27735, rickjle_0, rongg_65, rsdygt_tsedf, SIO-motor, tangyuanyou0, tianyou-2022, tong_5614, tzyh2501, wangmingqian, ware997, wdnlrfpzif0405, weilaikezai, wrcu9564, yishaoshop, ytjfgvvdge, zhangdongzhuo, zhangkai0, zhonghan0, zhouchunxia, zsh_76, Jayus costumes, JinYu.LTD and Newstar Co. Ltd added to case caption.

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for temporary restraining order[10]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[11]

DECLARATION of Alice Pang regarding memorandum in support of motion[11]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Exhibit 3 Parts 1-2 regarding declaration[13]

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for miscellaneous relief[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[15], motion for temporary restraining order[10], motion for leave to file[3] before Honorable Jorge L. Alonso on 11/27/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [10] [15] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $58,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 11/27/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 11/25/2024. Notice mailed by Judge's staff

Registry Deposit Information Form by PRL USA Holdings, Inc., Ralph Lauren Corporation

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Hannah Alexa Abes

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for extension of time of Temporary Restraining Order

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of extension of time[23]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[24]

NOTICE of Motion by Marcella Deshonda Slay for presentment of extension of time[23] before Honorable Jorge L. Alonso on 12/5/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiffs' Ex Parte Motion to extend the temporary restraining order 23 is granted. The temporary restraining order is extended to 12/23/24. Motion hearing date of 12/5/24 is stricken. Notice mailed by Judge's staff

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for preliminary injunction

Exhibit A

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for preliminary injunction[28]

Declaration of Marcella D. Slay

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[28] before Honorable Jorge L. Alonso on 12/17/2024 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by PRL USA Holdings, Inc., Ralph Lauren Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/11/2024, answer due 1/1/2025.

Declaration of Hannah A. Abes

Exhibit A

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Kahlia Roe Halpern

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 12/17/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [28] is granted. Enter preliminary injunction order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status hearing set for 1/22/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 12/17/2024. Notice mailed by Judge's staff

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 Honorable Virginia M. Kendall on 12/20/2024: Mailed notice.

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for entry of default, MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for entry of default, motion for default judgment, 40

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, 40 before Honorable Jorge L. Alonso on 1/14/2025 at 09:30 AM.

(Exhibit A)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 1/14/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Thomas Joseph Juettner

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants 40 is granted. Enter Final Default Judgment Order. Status hearing previously set for 1/22/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 1/14/2025. Notice mailed by Judge's staff