2025-cv-04039

COMPLAINT filed by Bulgari, S.p.A.; Filing fee $ 405, receipt number AILNDC-23346301.

Exhibit 1

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Schedule A regarding complaint[1]

MOTION by Plaintiff Bulgari, S.p.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bulgari, S.p.A.

Notice of Claims Involving Trademarks by Bulgari, S.p.A.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Rachel Meira Ackerman

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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. (qrtr,)

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

NEW PARTIES: Guangzhou Jiaqi Boutique Trading Co., Ltd., Henan Haikehong Import And Export Trade Co., Ltd., Shangmeng (Guangzhou) E-Commerce Co., Ltd., Yiwu Ohmys E-Commerce Firm (individual Business), Yiwu Taohuang E-Commerce Co., Ltd., Zaoqiang Dounty Daying Town Caoyi Fur Factory, A1P5BQ1RWZ1HUM, BoLBH, Cocoon Vietnam, DAGOKATU85, Family_Tell, Fat baby, FFUXIAO, flower STORE, hoangvushop2704, Hofar direct, hongnannan, JBANG, Linzeyi Store, LTCXCXCD, LTVIEMLD, NINGJINGJ, NQVN, Revitalizing China, Rose Mouse Store, shanxizhengxinweizaishengziyuanyouxiangongsi, Shcyee, taiyuanhongtukejizhongxin, TRANSTPDSJAF, Vancy Utopia, XAHH, YOURSFS, YRMLYMOP, yuanjieyao, YUN CLOUD, yuyuye, ZEJINGPEIJIAN, dengfa25, fashiongrace1, tam2ara5, marthamet01 and repwatchplug.com added to case caption.

MOTION by Plaintiff Bulgari, S.p.A. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Bulgari, S.p.A. in support of motion for temporary restraining order 13

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

DECLARATION of Laurence Morel-Chevillet regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Exhibit 2 - Part 1 regarding declaration 16

(Exhibit 2-1)

MOTION by Plaintiff Bulgari, S.p.A. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Bulgari, S.p.A. 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 miscellaneous relief 18, motion for leave to file 3, motion for temporary restraining order 13 before Honorable Jorge L. Alonso on 4/23/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [13] [18] 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 $42,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 4/23/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/22/2025. Notice mailed by Judge's staff

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Bulgari, S.p.A.

Registry Deposit Information Form by Bulgari, S.p.A.

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

SURETY BOND in the amount of $ 42,000.00 posted by Bulgari, S.p.A.

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

MOTION by Plaintiff Bulgari, S.p.A. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Bulgari, S.p.A. in support of motion for preliminary injunction[29]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[29] before Honorable Jorge L. Alonso on 5/6/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/1/2025, answer due 5/22/2025.

Declaration of Rachel M. Ackerman

Exhibit A

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Marcella Deshonda Slay

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/6/25 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

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's 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. Telephonic status hearing set for 6/5/25 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 5/6/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Trevor Christian Talhami

MOTION by Plaintiff Bulgari, S.p.A. for entry of default, MOTION by Plaintiff Bulgari, S.p.A. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Bulgari, S.p.A. in support of motion for entry of default, motion for default judgment[42]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[42] before Honorable Jorge L. Alonso on 6/5/2025 at 09:30 AM.

Exhibit A

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment to all remaining Defendants [42] 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 6/5/2025. Notice mailed by Judge's staff

MAILED trademark report with certified copy of minute order dated 6/5/25 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order, terminated case[48] in the amount of $200,000 as to certain defendant

NOTICE of withdrawal of bond 27 by John Summerfield