2025-cv-02891

COMPLAINT filed by PRL USA Holdings, Inc., Ralph Lauren Corporation; Filing fee $ 405, receipt number AILNDC-23229683.

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 Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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.

NEW PARTIES: Anhui Twinkle Tourist Articles Co., Ltd., Guangzhou Rundayu Trading Co., Ltd., Huzhou Hanyi Pony Clothing Co., Ltd., Ningxiang City Dingxintai Clothing Store, Shenzhen Zamfun Garment Accessories Co., Ltd., Yiwu Motty Garment Co., Ltd., DAOLICHCOI95, anqingyixushang-0, b738071, d-154-fg15, didk990, faf533, fanminsfg, fanrong Changsheng, fxpy5751, h001121, happ, hengfengtaijewelry, hkd668, Honest Mitolin, JaimesGolfoutlet, Jianguo Costume, kemifz8, meilan_x1, niceagain-8, niceflourishing, niceoutstanding, nidfhkl, pcsom501, sky zhi, t-888827, wudishiduomejimo, xd1212, xinyu9945 and yfy948 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[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Alice Pang regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Exhibit 3 regarding declaration[14]

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[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[11], motion for miscellaneous relief[16], motion for leave to file[3] before Honorable Jorge L. Alonso on 3/26/2025 at 09:30 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [11] [16] 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 $35,000--$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 3/26/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 3/25/2025. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing set for 4/8/25 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

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

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation

SUMMONS Issued (Court Participant) as to The Partnerships and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 35,000.00 posted by PRL USA Holdings, Inc., Ralph Lauren Corporation. (Document not imaged) (Received via the Clerk's Office drop box on 03/28/2025.)

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for preliminary injunction[29]

Declaration of Marcella D. Slay

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[29] before Honorable Jorge L. Alonso on 4/8/2025 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 4/3/2025, answer due 4/24/2025.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 5/8/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiffs' Motion for entry of a preliminary injunction as to certain Defendants [29] 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. 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 4/8/2025. Notice mailed by Judge's staff

SUMMONS Returned Executed by Ralph Lauren Corporation, PRL USA Holdings, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/9/2025, answer due 4/30/2025.

Declaration of Hannah A. Abes

(Exhibit A)

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, [36]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[37]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, [36] before Honorable Jorge L. Alonso on 5/8/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Lucas Allen Peterson

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiffs' Motion for entry of default and default judgment as to all remaining Defendants 36 is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 5/8/2025. Notice mailed by Judge's staff