2026-cv-00909

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-24645397.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-2 regarding complaint 1

Exhibit 3-1

(Exhibit 3-2)

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 Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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 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

Exhibit 3-1

(Exhibit 3-2)

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 temporary restraining order 12, motion for miscellaneous relief 17, motion for leave to file 4 before Honorable Elaine E. Bucklo on 2/4/2026 at 09:45 AM.

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 Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 4 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 12 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 17 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 2/17/2026, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 2/10/2026. 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 of the expiration of the TRO. 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 status hearing on 3/17/2026 at 9:45 a.m. (to track the case only, no appearance is required). By 3/10/2026 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 2/2/2026. 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

SURETY BOND in the amount of $10,000.00 posted by Chrome Hearts LLC

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 Elaine E. Bucklo on 2/13/2026 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's ex parte motion to extend the temporary restraining order 30 is granted to 3/2/2026. 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 35

(Declaration of Trevor C. Talhami)

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction 35 before Honorable Elaine E. Bucklo on 2/27/2026 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 2/24/2026, answer due 3/17/2026.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction 35 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint 3, Exhibit 3 to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Mario Lejtman 16 and the TRO 25. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 2/27/2026. Mailed notice.

NEW PARTIES: A341XX7EWZ3VSL, aizhouyistore, CHANGCAN, ChaoHz, HANFENGYUN-US, heetao, Hoangasdf, Jianshijingkaiqushenfushangmao, LIUYANGSOPH, LYY1, LZYZY SHOP, TaiYuanHuiYueWenHuaChuanMeiYouXianGongSi, Wen Jun, xinyexianangtaishangmaoyouxiangongsi, YOUGEETU, yuyongkai, ZXYDKMHDP, kkchmade1, kklove.shoes, a Singing and advancing a, Accessorieswu, ALPAKION, American Cap Co, Aoren Malll, benchaoshipin, BIU FFF, Buy a bag shop, caiwenjieshipin, CHUKTY, CYichen Shop, DamaChap, DIY Corner Local, dtdtdtdt, EasyVision Depot, ElevateBiteB, Fine Liu Jewelry Ornaments, FrameFable Shop, GBKSLO, GreedGod, hanjinshipin, HARLOW CO, HHHVSDX, HONEY LANE, Hooewgq, hupengshipin, Kat Dollar Shop, KDFSAIB, LiLin shop, Linkone shopone, Ljodf, Luxury Jewelry Market, MyLons, Nemesia, NoveltyMall, Oevgs, Petal Jewels, PETITE KORA Jewelry, PIAOXUE, qinfangfang, QuickGlow Goods, SATIN SHINE, sdfgfvcas, shipinliuxu, SKYSTIME, taoranshipin, Top Hat Co, TreasureWei, tuhaoshipin, VINE CHARM, Wangmingta, Wangweiguo, WILD GLEAM COLLECTION, WISHING WELL Bag, WM FCZM, xiaoganyifanw, XUAMAN, XYLON GLIMMER, YFPC, Yokokk, Yu fu shihat, ZBLjj, ZiJing Co, Abouthexx Shop, Time Wave Island Jewelry, chclove.com, Modala24, skullsaint.com, tbstar.vip, tbstar.vip, tbstar.vip, Guangzhou yuantou factory, NFT&OIC, budgetshoess and ypd2023 added to case caption. (Text entry; no document attached.)

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Madeline Halgren

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

STATUS Report Pursuant to 24 by Chrome Hearts LLC

(Exhibit A)

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

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. Pending defendants responsive pleading, Plaintiff will move for default judgment against remaining non-dismissed defendants at a later date where appropriate. Status hearing is reset for 4/16/2026 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 4/9/2026. The court will enter an order in response to the status report. 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[47]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[47] before Honorable Elaine E. Bucklo on 3/25/2026 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendants ALPAKION, HARLOW CO, HONEY LANE, Petal Jewels, SATIN SHINE, VINE CHARM, WILD GLEAM COLLECTION, XYLON GLIMMER, ZiJing Co by Adam Edward Urbanczyk

MOTION by Defendants ALPAKION, HARLOW CO, HONEY LANE, Petal Jewels, SATIN SHINE, VINE CHARM, WILD GLEAM COLLECTION, XYLON GLIMMER, ZiJing Co for extension of time

NOTICE of Motion by Adam Edward Urbanczyk for presentment of extension of time[52] before Honorable Elaine E. Bucklo on 3/25/2026 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants ALPAKION, HARLOW CO, HONEY LANE, Petal Jewels, SATIN SHINE, VINE CHARM, WILD GLEAM COLLECTION, XYLON GLIMMER, ZiJing Co's opposed motion for extension of time to respond to Plaintiff's Complaint [52] is granted to 4/13/2026. Scheduling Conference is set for 5/11/2026 at 9:45 a.m. (to track the case only; no appearance is required). The joint Rule 26(f) planning report is due 5/4/2026. (The form of the report can be found on Judge Bucklo's webpage at www.ilnd.uscourts.gov.) The Court will enter a schedule based on the report. Mailed notice.