2026-cv-00319

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-24581069.

Exhibit 1

Exhibit 2

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

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 Matthew F. Kennelly. 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.

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]

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]

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 Matthew F. Kennelly: Plaintiff's motion to file under seal [4] and motion for electronic service [17] are granted. Plaintiff's ex parte motion for entry of a temporary restraining order [12] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 2/6/2026 at 9:05 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 2/3/2026. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 1/23/2026. Mailed notice.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to a Certain Defendant

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

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to a Certain Defendant

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

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[30]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[31]

SURETY BOND in the amount of $ 10,000.00 posted by Chrome Hearts LLC (Document not scanned).

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to extend the temporary restraining order [30] is granted; the telephonic preliminary injunction hearing set for 2/6/2026 is vacated and reset to 2/20/2026 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 2/17/2026. The Court advises that it may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[34]

Declaration of Trevor C. Talhami

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/4/2026, answer due 2/25/2026.

Declaration of Luana Faria de Souza

Exhibit A

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

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or a response to the complaint or the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 2/20/2026 is vacated. Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. 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. 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 telephonic status hearing on 4/20/2026 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 4/13/2026. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 2/18/2026. Mailed notice.

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

ATTORNEY Appearance for Defendant bluntcases.com by Matthew L. De Preter (De Preter, Matthew)