2025-cv-09031

COMPLAINT filed by Hublot SA; Filing fee $ 405, receipt number AILNDC-23822126.

Exhibit 1 to the Complaint

Exhibit 1 to the Declaration of Paul Kossof

(Exhibit 1 to the Declaration of Nicolas Lambert)

Supplement Memorandum in Support of Motion for Electronic Service

(Supplement Memorandum in Support of Motion for Temporary Restraining Order)

CIVIL Cover Sheet

Exhibit 2 to the Complaint

Exhibit 2 to the Declaration of Paul Kossof

Declaration of Paul Kossof in Support of Motion for Electronic Service

ATTORNEY Appearance for Plaintiff Hublot SA by Paul Joseph Kossof

Exhibit 3 to the Complaint

(Exhibit 3 to the Declaration of Paul Kossof)

Exhibit 1 to the Declaration of Paul Kossof in Support of Motion for Electronic Service

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hublot SA

(Exhibit 4 to the Complaint)

(Exhibit 2 to Declaration of Paul Kossof in Support of Motion for Electronic Service)

Notice of Claims Involving Trademarks by Hublot SA

Trademark Report by Hublot SA

DECLARATION of Paul Kossof

MOTION by Plaintiff Hublot SA to seal Schedule A, Exhibit 2 to the Declaration of Nicolas Lambert, and Plaintiffs Memorandum Establishing That Joinder Is Proper

SEALED DOCUMENT by Plaintiff Hublot SA Schedule A

DECLARATION of Nicolas Lambert

SEALED DOCUMENT by Plaintiff Hublot SA Exhibit 2 to the Declaration of Nicolas Lambert

SEALED DOCUMENT by Plaintiff Hublot SA Plaintiff's Memorandum Establishing that Joinder is Proper

MOTION by Plaintiff Hublot SAfor electronic service of process.

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.)

MOTION by Plaintiff Hublot SA for temporary restraining order

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal [8], motion for electronic service of process [13], and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [14] are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and 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 effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 10/31/25 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jeffrey I Cummings on 9/4/2025. Mailed notice.

MOTION by Plaintiff Hublot SA for preliminary injunction