2025-cv-13423

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-24291225.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-3 regarding complaint 1

Exhibit 1

Exhibit 2

(Exhibit 3)

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 Robert W. Gettleman. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Manish S. Shah for all further proceedings pursuant to Local Rule 28 USC 294(b). The receiving judge will receive equalization credit. Mailed notice

(Request for Reassignment) (gmm)

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 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

DECLARATION of Mario Lejtman regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-3 regarding declaration 15

Exhibit 3-1

Exhibit 3-2

(Exhibit 3-3)

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 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 17, motion for temporary restraining order 12, motion for leave to file 4 before Honorable Manish S. Shah on 11/13/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions are granted and no appearance is necessary. Enter Sealed TRO. The court notes that it has some doubts that every cross-shaped or fleur-de-lis-shaped product is infringing of plaintiff's marks and plaintiff's election will influence the court's evaluation of statutory damages across all defendants. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 11/12/2025. Notices Mailed.

Registry Deposit Information Form by Chrome Hearts LLC

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

SURETY BOND in the amount of $50,000.00 posted by Chrome Hearts LLC (Document not scanned). (bi,)

ATTORNEY Appearance for Defendant Artdone by Alexander Warden

MOTION by Plaintiff Chrome Hearts LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Chrome Hearts LLC in support of extension of time 29

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 30

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time 29 before Honorable Manish S. Shah on 11/25/2025 at 09:45 AM.

MOTION by Defendant Artdone to dismiss for misjoinder

(Supplement Memorandum of Law)

ATTORNEY Appearance for Defendant FLOERNS ONLINE STORE by Michael P. Adams

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 29 is granted, and no appearance is necessary. The TRO is extended to 12/10/25. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff shall respond to the motion to dismiss by 12/2/25 and defendant may reply by 12/9/25. The court will rule by cm/ecf or at any hearing on a motion for preliminary injunction. Notices Mailed.

Joint Notice of Settlement by Chrome Hearts LLC

MINUTE entry before the Honorable Manish S. Shah: The motion to dismiss [33] is terminated as moot, pending settlement. Notices Mailed.

STIPULATION of Dismissal as to a Certain Defendant (Joint)

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[41]

Declaration of Trevor C. Talhami

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[41] before Honorable Manish S. Shah on 12/9/2025 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/4/2025, answer due 12/25/2025.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held on 12/9/25. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction [41] is granted. Enter Order. Law Firm of Greer, Burns & Crain Ltd. 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. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Manish S. Shah on 12/9/2025. Mailed notice.

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