2025-cv-06119

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-23563089.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Chrome Hearts LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chrome Hearts LLC

Notice of Claims Involving Trademarks by Chrome Hearts LLC

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Heather K. McShain. 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: aguanxiaodian, ainuomeini, botoushiouqiwangshanggouwushanghang, chaolehui, Classic+ Glasses, Cliffora Direct, datongshimujiafangdichanjingjiyouxiangongsi, haerbinshengtujixiezhizaoyouxiangongsi, JGBSW, jinghuazhaungshiyongshun, JOEZITON, Kaifei Shun, lijiaoashop, liliping52552, MuiMui Handmade Art Grocery Store, North Animal, Organic Oasisi, Qingsheng Pei, QINZHENGHU, SANSANDEXIAODIAN, Sealinkea, shanxiyiyiyouxuandianzishangwugongzuoshi, Sianyu-us, tengzhoushiqiunashangmaoyouxiangongsi, Tianhe Leap, xiyangxianxinbaihuishangmaoyouxiangongsi, YiKunBaiHuo, YuChenRui-us, alikes_m1, cauchy_clothes.a, leidyagudelomunoz, poppystore_ww, shopping__baby3, wu_stockxxs55, Aisha sin, AlbaCouture, Aurora Boutique Menswear, Black Horse Phone Case, boeroadgood, ChicGuyzTees, CoCo Fashion Club, Eaca T shirt shop, Eaca T shirt two, GOOGMAN T, Happy Seller ONE, High Wind New Digital, Hip hop Lil Dings Jewel Shop, Hip hop Street Fashion, HSClothing local, KUHELA, loveclothers, Nomocore, NovoLumeng, ShopYL Local, SupervimLym, XYCASE, chromeworld.co, thechrome-hearts.com, tk-remake.us, repsbrothers and zzaccaheusvip added to case caption.

MOTION by Plaintiff Chrome Hearts LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Chrome Hearts LLC in support of motion for temporary restraining order[11]

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

DECLARATION of Mario Lejtman regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-3 regarding declaration[14]

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

MEMORANDUM by Chrome Hearts LLC in support of motion for miscellaneous relief[16]

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

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

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's pending motion 3 16 are granted. Plaintiff's motion for a temporary restraining order 11 is granted. Enter Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 6/4/2025.

Registry Deposit Information Form by Chrome Hearts LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Chrome Hearts LLC

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

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to Certain Defendants

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[28]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/13/2025, answer due 7/4/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Response to motion for preliminary injunction [29] due 7/14/25. Status report due 7/21/25. Mailed notice.

SURETY BOND in the amount of $ 98,000.00 posted by Chrome Hearts LLC

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

ATTORNEY Appearance for Defendants EclatVibe, ChromaChronicle Shop, Nympha Shop, Urbanoir, OCHOICE, AlbaCouture, HUGGC HUC, EchoSculpt SHOP, Driftwood Shop by Timothy Tiewei Wang

Exhibit A

MOTION by Defendants AlbaCouture, ChromaChronicle Shop, Driftwood Shop, EchoSculpt SHOP, EclatVibe, HUGGC HUC, Nympha Shop, OCHOICE, Urbanoir for extension of time to file answer regarding complaint[1] Unopposed

MINUTE entry before the Honorable Mary M. Rowland: Defendants AlbaCouture, ChromaChronicle Shop, Driftwood Shop, EchoSculpt SHOP, EclatVibe, HUGGC HUC, Nympha Shop, OCHOICE, and Urbanoir's unopposed motion for extension of time to file answer [36] is granted. Defendants AlbaCouture, ChromaChronicle Shop, Driftwood Shop, EchoSculpt SHOP, EclatVibe, HUGGC HUC, Nympha Shop, OCHOICE, and Urbanoir to answer by July 28, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

STATUS Report Pursuant to [31] by Chrome Hearts LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status report [40]. The court grants plaintiff's motion for preliminary injunction [28] that has not been opposed by any of the defendants who have been served. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4.Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 7/23/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to Certain Defendants

MOTION by Plaintiff Chrome Hearts LLC for entry of default, MOTION by Plaintiff Chrome Hearts LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for entry of default, motion for default judgment[44]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Mary M. Rowland: Response to motion for default judgment is due 8/27/25. Status report due 9/3/25 Mailed notice.

ATTORNEY Appearance for Defendant Nomocore by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Nomocore

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

MINUTE entry before the Honorable Mary M. Rowland: Defendant Nomocore's unopposed motion for extension of time to file answer [50] is granted. Defendant Nomocore is to answer or otherwise plead in response to the complaint by 8/26/25. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

STATUS Report Pursuant to [47] by Chrome Hearts LLC

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the status report [55]. The court grants the unopposed motion for default judgment [44]. Enter order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 9/4/2025. Mailed notice.

MAILED trademark report with certified copy of minute order dated 9/4/25 to Patent Trademark Office, Alexandria VA.

MAILED copyright report with certified copy of minute order dated 9/4/25 to Registrar, Washington DC.

FULL SATISFACTION of Judgment regarding Default Judgment[57] in the amount of $50,000 as to certain defendants