2025-cv-02803

COMPLAINT filed by PRL USA Holdings, Inc., Ralph Lauren Corporation; Filing fee $ 405, receipt number AILNDC-23219960.

Exhibit 1

Exhibit 2

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

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

CASE ASSIGNED to the Honorable Georgia N Alexakis. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED copyright report to Registrar, Washington DC

AMENDED complaint by PRL USA Holdings, Inc., Ralph Lauren Corporation against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Amended Schedule A regarding amended complaint, [14]

Notice of Withdrawal of Plaintiffs Motion for Leave to File Under Seal [3] by PRL USA Holdings, Inc., Ralph Lauren Corporation

MINUTE entry before the Honorable Georgia N Alexakis:In light of plaintiff's withdrawal of its motion for leave to file under seal [16], the motion for leave to file under seal [3] is stricken.

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 5/27/25 at 9:30 a.m. in person in Courtroom 1719. By 5/20/25,the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for discovery Expedited

Exhibit 1

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[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[20], motion for discovery[19] before Honorable Georgia N Alexakis on 5/19/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's motions for expedited discovery [19] and electronic service of process [20] are granted. No appearance is required on 5/19/25. The Court finds that expedited discovery is warranted to identify defendants. The Court also finds that electronic service does not violate any treaty and is consistent with due process because it is an effective way to communicate with the online marketplace defendants. The Court decides these issues, however, without the benefit of adversarial presentation. If any defendant were to appear and object, the Court will take a fresh look at the issues of electronic service and expedited discovery as well as any issues related to personal jurisdiction. Enter Order, as modified by the Court.

ORDER Signed by the Honorable Georgia N Alexakis on 5/14/25.

SUMMONS Submitted (Court Participant) for defendant(s) yichangshimenglixi and the Individuals and Entities Operating yichangshimenglixi by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation

SUMMONS Issued (Court Participant) as to Defendants The Individuals and Entities Operating Yichangshimenglixi, Yichangshimenglixi

SUMMONS Returned Executed by PRL USA Holdings, Inc., Ralph Lauren Corporation as to The Individuals and Entities Operating Yichangshimenglixi on 5/20/2025, answer due 6/10/2025; Yichangshimenglixi on 5/20/2025, answer due 6/10/2025.

Declaration of Hannah A. Abes

Exhibit A

STATUS Report Pursuant to [18] by PRL USA Holdings, Inc., Ralph Lauren Corporation

Exhibit A

MINUTE entry before the Honorable Georgia N Alexakis: The Court has reviewed plaintiff's initial status report 29, which reports that defendant was not served until 5/20/25. Defendant's answer or response to plaintiff's complaint is now due 6/10/25 28. The Court therefore resets the initial status hearing to 6/17/25 at 9:30 a.m. If the defendant has not appeared by that date, plaintiff is directed to file a motion for entry of default by 6/24/25.

MINUTE entry before the Honorable Georgia N Alexakis: The docket reflects that defendant has been served [28] but has not entered an appearance or answered or otherwise responded to plaintiff's complaint. Given these circumstances, the Court vacates the 6/17/25 status hearing. The 6/24/25 deadline for plaintiff to file a motion for entry of default [30] stands.

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, [32]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

Exhibit 1

NOTICE of Motion by Justin R. Gaudio for presentment of motion for entry of default, motion for default judgment, [32] before Honorable Georgia N Alexakis on 6/24/2025 at 09:30 AM.

Exhibit A

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff seeks entry of default as to defendant yichangshimenglixi, the remaining defendant in this matter. Defendant yichangshimenglixi has failed to plead or to otherwise appear to defend against this action. Accordingly, default against defendant yichangshimenglixi is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by the Defaulting Defendant must be filed on or before 7/2/25. Plaintiff must serve this minute order upon the Defaulting Defendant within one business day of its entry on the docket and must promptly file proof of that service. The Court re-sets the hearing on plaintiff's motion seeking default judgment as to the Defaulting Defendant from 6/24/25 to 7/15/25 at 9:30 a.m.

CERTIFICATE of Service by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation regarding terminate hearings, set/reset hearings, [36]

Exhibit A

MOTION by defendant Tommy Izmerli to continue (reschedule) or extended time (Received via pro se online portal on 06/20/25.)

Proposed Order

NOTICE by defendant Tommy Izmerli of court date for motion [38] (Received via pro se online portal on 06/20/25.)

NOTICE of Correction regarding notice of motion[39], MOTION to continue [38]

MINUTE entry before the Honorable Georgia N Alexakis: Defaulting Defendant (yichangshimenglixi) has not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion 32 is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's intellectual property rights irreparably harms plaintiff and confuses the public. Because this infringement was willful, and after considering the value of plaintiff's brand, the price-point of the infringing products, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $25,000 is an appropriate award of statutory damages against the Defaulting Defendant. Enter Final Judgment Order, as modified by the Court. Civil case terminated.

FINAL Judgment Order Signed by the Honorable Georgia N Alexakis on 7/14/25.