2026-cv-00497

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-24605314.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-2 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 Virginia M. Kendall. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category Two).

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 1-2 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]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[17], motion for leave to file[4], motion for temporary restraining order[12] before Honorable Virginia M. Kendall on 1/22/2026 at 09:30 AM.

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 1/22/2026. Plaintiff's Motion for Temporary Restraining Order [12] is granted. Temporary Restraining Order shall remain in effect up to and including 2/5/2026. Status hearing set for 2/5/2026 at 9:30 AM. Sealed Order to follow. Plaintiff's Motions for leave to file under seal [4] and for electronic service of process [17] are granted. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 1/22/2026. Mailed notice

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 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]

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time[30] before Honorable Virginia M. Kendall on 2/5/2026 at 09:30 AM.

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

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for extension of Temporary Restraining Order [30] is granted. Temporary Restraining Order shall remain in effect up to and including 2/19/2026. Status hearing set for 2/5/2026 is reset for 2/25/2026 at 9:30 AM. Motion hearing set for 2/5/2026 is stricken. Mailed notice

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[36]

Declaration of Trevor C. Talhami

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[36] before Honorable Virginia M. Kendall on 2/10/2026 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/5/2026, answer due 2/26/2026.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 2/10/2026. Plaintiff's Motion for Preliminary Injunction [36] is granted. Order to follow. Status hearing set for 3/11/2026 at 9:30 AM. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 2/10/2026. Status hearing set for 2/25/2026 is stricken. Mailed notice

NEW PARTIES: A2WK5T2J6L5D3Z, AllGoods shop, fashion wigs, Giftall Shop, HANGZHOU LIHI ECO-TECH CO.,LTD., JieShengYuanKeJi, MengXS Jewelry, NICEPRODUCTS, Oriental Chinese elements, Sen Fei, Warshion, WJBFC, XiaoHaozi, YSLYLX-SHOP, ZHEXUNDIAN, zhong lian shang mao, kkchmade1, A piece of firewood, A vbdvbhdf A, Aazhua, Ad Astra Jewelry, ArtisanGlow Goods, Aurora Jewel, BLOOM GLAM, BRISK SPARK, Caelum Jewelry, CORAL CHROME, CYGG Jewelry, DALE STONE, DDDxl, Deal Depot Q, Dreamy Sleep, EMERALD ALLEY, Exquisite persimmon vine, Fang Commodity A, Freshewelry, GALE SHINE, Gem Glamour, INFINITE BIJOUX, JIVE SPARK, JOLT GLOW, JUYANG Jewelry, LCYZ Jewelry, LIAOMEIA, Lightcollecting mirror language, Lune Co, MAPLE GLEAM, MAPLE PEARL, MYSTIC LUSTER, NEBULA GLINT, NiYou Picks, NOCTURNE GEMS, ORCHID SHINE, Petite Charm, pumpkins are ripe, PURE EDGE, QD forsythia, Qingni Accessory, Qnieming, QUEENSWAY GLOW, QUILT THREAD, QUVAER GEMS, Radiant Jewelry Trade, RIPTIDE SHINE, SOLARA JEWELRY, Stellary Accents, SUMMIT CHARM, THUNDER GEM, TiannYi, UTOPIAN GLOW, UUGE, VIBE MINIMAL, wangxinwang local, WAVE SPARK, WILLOW GEM, WLCL Jewelry, WMESS, WMESSS, Wnie, Wnieheng, Worry Relief ShopWZQ, Worry Relief ShopXzq, Xionglj, XOCHI GEMS, YEXU SEXY, yutingshishang, ZEST JEWELS, ZZRS Jewelry, AeroGadgetpro, Fate Muse Jewelry, Soft snow and Ahe added to case caption.

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

ATTORNEY Appearance for Defendants CYGG Jewelry, JUYANG Jewelry, LCYZ Jewelry, Radiant Jewelry Trade, WLCL Jewelry, ZZRS Jewelry by Mingbo Ye

MOTION by Defendants WLCL Jewelry, CYGG Jewelry, LCYZ Jewelry, JUYANG Jewelry, Radiant Jewelry Trade, ZZRS Jewelry to dismiss for improper joinder, or in the alternative, to sever claims

Declaration of Zhen Wu

Text of Proposed Order

NOTICE of Motion by Mingbo Ye for presentment of motion to dismiss, [44] before Honorable Virginia M. Kendall on 3/5/2026 at 09:30 AM.