2025-cv-03696

COMPLAINT filed by Kendra Scott, LLC; Filing fee $ 405, receipt number AILNDC-23310888.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Luana Faria de Souza

Exhibit A

Declaration of Rachel S. Miller

Exhibit A

Exhibit A

Exhibit A

Exhibit A

Declaration Jianqing Cai

Exhibit 1

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Schedule A regarding complaint[1]

Exhibit A

Exhibit 2

Exhibit 2-1

MOTION by Plaintiff Kendra Scott, LLC for leave to file under seal

Exhibit 2-2

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kendra Scott, LLC

Notice of Claims Involving Trademarks by Kendra Scott, LLC

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.)

NEW PARTIES: Anker (Chongqing) Import And Export Trading Co., Ltd., Dezhou Yarno Trading Co., Ltd., Dongguan City Rewin Gift Company Limited, Dongguan Xinjinxin Jewelry Co., Ltd, Guangzhou Flora Jewelry Co., Ltd., Guangzhou Mingshixuan Jewellery Co., Ltd., Guangzhou Tess Jewelry Co., Ltd., Guangzhou ZNYJ Co., Ltd., Haifeng County Ketang Town Hongmei Jewelry Firm, Katya Jewelry (dongguan) Co., Ltd., Nanyang Guiman Trading Co., Ltd., Qingdao Singsun Crafts Co., Ltd., Shenzhen Jingrun Jewelry Co., Ltd, Sichuan Chendang Technology Co., Ltd., Universe Electronic Commerce Co., Ltd., Xi'an Guozi Trading Co., Ltd, Xiamen Wood Stone Zhizao New Material Technology Co., Ltd., Yiwu Fanhua Jewelry Co., Ltd., Yiwu Qitong Trading Firm, Yiwu Quantuo Trading Co., Ltd., Yiwu Zhiyue Trade Co., Ltd., Zhejiang Lezai Daily Necessities Co., Ltd., baodingranbanmaoyi, DBSEBAY, DHAutoLife, hahahaEvyday, HOOOWA, JILULU, Kinni666, NIu8866Man, TaiGuFa, TaiGuJi, TRONG HIEU QN, wanrongxiangaoliangfengjiatingnongchang, Wryhaul (Delivery on 7-14 days), zhanghengshangmao, asuvpa_56, bgtvskhyrus_0, mtqlxg24, osbn4440, umianbiaom-0, xiongxuemei489, FITOVER JEWELRY, GGIRL JEWELRY, nfuxi, HUMAO local, I you win nn, mz-girl, yong li KKK local, Zhao Xin nn, anqi, ChangJieWireless, Friyu, Having, helian shop, Hopeoy, HuangYuYing, ingdishangmaoyiSWDWSF, Jewelry 68, jinanankehuawangluokeji, joker.xue Co.Ltd, JUBAOB, Kanakura, Keepwin, Lilongbaohui, LYDbest, MoXun Llc, Sailor Moon, SHAOXU, Tefch, Yriper LLC, yuhuang Co.ltd and ZHAPNG added to case caption. (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 Kendra Scott, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Kendra Scott, LLC in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Adrienne T. Montes regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Exhibit 2 - Parts 1-2 regarding declaration[16]

MOTION by Plaintiff Kendra Scott, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Kendra Scott, LLC in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[13], motion for miscellaneous relief[18] before Honorable Elaine E. Bucklo on 4/11/2025 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, 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 4/29/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/22/2025. 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 5/29/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 5/22/2025 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.

Registry Deposit Information Form by Kendra Scott, LLC (Faria De Souza, Luana)

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

INJUNCTION BOND in the amount of $10,000 posted by Kendra Scott, LLC.

MOTION by Plaintiff Kendra Scott, LLC for extension of time of Temporary Restraining Order (Faria De Souza, Luana)

MEMORANDUM by Kendra Scott, LLC in support of extension of time[27] (Faria De Souza, Luana)

DECLARATION of Luana Faria de Souza regarding memorandum in support of motion[28] (Faria De Souza, Luana)

NOTICE of Motion by Luana Faria De Souza for presentment of extension of time[27] before Honorable Elaine E. Bucklo on 4/25/2025 at 09:45 AM. (Faria De Souza, Luana)

MOTION by Plaintiff Kendra Scott, LLC for preliminary injunction

MEMORANDUM by Kendra Scott, LLC in support of motion for preliminary injunction[32]

NOTICE of Motion by Luana Faria De Souza for presentment of motion for preliminary injunction[32] before Honorable Elaine E. Bucklo on 5/7/2025 at 09:45 AM.

SUMMONS Returned Executed by Kendra Scott, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/30/2025, answer due 5/21/2025.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order [27] is granted. Plaintiff's motion for entry of a preliminary injunction [32] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Seller Aliases screenshots attached to the Declaration of Adrienne T. Montes [17], and the TRO [23]. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 5/6/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Kendra Scott, LLC as to certain defendants (Faria De Souza, Luana)

STATUS Report Pursuant to [22] by Kendra Scott, LLC

MOTION by Defendants Kanakura and Keepwin for extension. (Received via pro se online portal on 5/24/25.)

ATTORNEY Appearance for Defendant ChangJieWireless by Christopher Paul Keleher

MOTION by Defendant ChangJieWireless for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[42] before Honorable Elaine E. Bucklo on 6/4/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff are engaged in settlement negotiations with a number of defendants. Plaintiff will move for default judgment against remaining non-dismissed defendants at a later date where appropriate. Status hearing is reset for 7/15/2025 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 7/8/2025. The court will enter an order in response to the status report. Defendants, the stores Kanakura (Doe.63); Keepwin (Doe.64) and 52 ChangJieWireless (ID:10002511001) motion for extension of time to answer or plead [41]; [42] is granted to 6/17/2025. Mailed notice.

ATTORNEY Appearance for Defendants I you win nn, Zhao Xin nn, yong li KKK local by Christopher Paul Keleher

MOTION by Defendants I you win nn, Zhao Xin nn, yong li KKK local for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[46] before Honorable Elaine E. Bucklo on 6/12/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants 47 I you win nn (634418217193590), 49 yong li KKK local (634418217436434), and 50 Zhao Xin nn (634418217570731)'s first motion for extension of time to answer or otherwise plead to Plaintiff's Complaint [46] is granted to 6/30/2025. Mailed notice.

MOTION by Plaintiff Kendra Scott, LLC to approve consent judgment as to Certain Defendants

NOTICE of Motion by Luana Faria De Souza for presentment of motion to approve consent judgment[49] before Honorable Elaine E. Bucklo on 6/20/2025 at 09:45 AM.

MOTION by Defendant ChangJieWireless for extension of time to file answer regarding complaint[1] (UNOPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[51] before Honorable Elaine E. Bucklo on 6/25/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Unopposed (second) motion of Defendant 52 Chang.JieWireless (10002511001) for extension of time to answer or plead to Complaint [51] is granted to 7/8/2025. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's agreed motion for entry of a consent judgment as to defendants Nos. 63 and 64 [49] is granted. Enter Consent Judgment. Mailed notice.

CONSENT JUDGMENT signed by the Honorable Elaine E. Bucklo on 6/20/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Kendra Scott, LLC as to certain defendants (Faria De Souza, Luana)

STATUS Report Pursuant to [44] by Kendra Scott, LLC

MOTION by Defendant ChangJieWireless to dismiss for lack of jurisdiction and insufficient service of process

ATTORNEY Appearance for Defendant ChangJieWireless by Longhao Wang

NOTICE of Motion by Longhao Wang for presentment of motion to dismiss/lack of jurisdiction[58] before Honorable Elaine E. Bucklo on 7/16/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: The Court sets the following briefing schedule on Defendant ChangJieWireless' (No. 52) motion to dismiss pursuant to Rules 12(b)(2) and 12(b)(5) [58]: Plaintiff's response is due by 7/30/2025. Defendant's reply is due by 8/13/2025. Ruling before the Honorable Elaine E. Bucklo on 9/18/2025 at 9:30 a.m. Mailed notice.

MOTION by Attorney Christopher Keleher to withdraw as attorney for ChangJieWireless. No party information provided

NOTICE of Motion by Christopher Paul Keleher for presentment of motion to withdraw as attorney[62] before Honorable Elaine E. Bucklo on 7/16/2025 at 09:45 AM.

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Rachel Meira Ackerman

MOTION by Plaintiff Kendra Scott, LLC to Conduct Jurisdictional Discovery for Defendant's Motion to Dismiss [58], and to Stay or Extend the Briefing Schedule [61]

DECLARATION of Rachel M. Ackerman regarding motion for miscellaneous relief[65]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[65] before Honorable Elaine E. Bucklo on 7/16/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Motion to withdraw counsel by Defendant ChangJieWireless (No. 52) [62] is granted. Christopher Keleher is hereby terminated as counsel for Defendant ChangJieWireless (No. 52). Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendant shall respond to plaintiff's motion to conduct jurisdictional discovery for defendant's motion to dismiss [58], and to stay or extend the briefing schedule [61] [65] by 8/1/2025. Ruling is set for 8/22/2025. The court will issue a ruling by mail. Mailed notice.

NOTICE of Voluntary Dismissal by Kendra Scott, LLC as to Certain Defendants (Faria De Souza, Luana)

MOTION by Plaintiff Kendra Scott, LLC to approve consent judgment as to Certain Defendants

MOTION by Plaintiff Kendra Scott, LLC for entry of default, MOTION by Plaintiff Kendra Scott, LLC for default judgment as to certain Defendants

MEMORANDUM by Kendra Scott, LLC in support of motion for entry of default, motion for default judgment[72]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[73]

NOTICE of Motion by Luana Faria De Souza for presentment of motion for entry of default, motion for default judgment[72], motion to approve consent judgment[71] before Honorable Elaine E. Bucklo on 7/23/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's agreed motion for entry of a consent judgment as to defendants Nos. 56 and 70 [71] is granted. Enter Consent Judgment. Plaintiff's motion for entry of default and default judgment as to all remaining defendants, with the exception of Defendant No. 52 (ChangJieWireless) [72] is granted. Enter Final Judgment Order. Mailed notice.

CONSENT JUDGMENT as to Defendants Hopeoy (Def. No. 56) and Tefch (Def. No. 70) signed by the Honorable Elaine E. Bucklo on 7/23/2025. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 7/23/2025. Mailed notice.

RESPONSE by Kendra Scott, LLC to MOTION by Defendant ChangJieWireless to dismiss for lack of jurisdiction and insufficient service of process [58] Preliminary

ATTORNEY Appearance for Defendant ChangJieWireless by Baruch Simcha Gottesman

MOTION by Attorney Longhao Wang to withdraw as attorney for ChangJieWireless. No party information provided

NOTICE of Motion by Longhao Wang for presentment of motion to withdraw as attorney[81] before Honorable Elaine E. Bucklo on 8/27/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Unopposed motion to withdraw counsel by Defendant ChangJieWireless (No. 52) 81 is granted. Longhao Wang is hereby terminated as counsel for Defendant ChangJieWireless. Mailed notice.