2026-cv-04061

COMPLAINT filed by Celine S.A.; Filing fee $ 405, receipt number AILNDC-24969049.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

(Exhibit 4 to the Complaint)

SEALED DOCUMENT by Plaintiff Celine S.A. Schedule A

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Celine S.A. by Paul Joseph Kossof

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Celine S.A.

Notice of Claim Involving Trademarks by Celine S.A.

Trademark Report by Celine S.A.

DECLARATION of Paul Kossof

Exhibit 1 to the Declaration of Paul Kossof

Exhibit 2 to the Declaration of Paul Kossof

(Exhibit 3 to the Declaration of Paul Kossof)

DECLARATION of Nicolas Lambert

(Exhibit 1 to the Declaration of Nicolas Lambert)

SEALED DOCUMENT by Plaintiff Celine S.A. Exhibit 2 to the Declaration of Nicolas Lambert

(Exhibit 2 to the Declaration of Nicolas Lambert (Part 2))

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

Schedule A to the Complaint by Celine S.A.

Exhibit 2 to the Declaration of Nicolas Lambert by Celine S.A.

(Exhibit 2 to the Declaration of Nicolas Lambert (Part 2))

MOTION by Plaintiff Celine S.A.for electronic service of process.

Supplement Memorandum in Support of Motion for Electronic Service

Declaration of Paul Kossof in Support of Motion for Electronic Service

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

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

MOTION by Plaintiff Celine S.A.for order directing clerk to issue summons.

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for miscellaneous relief, 13, motion for miscellaneous relief 14 before Honorable LaShonda A. Hunt on 4/21/2026 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. Upon review of the trademark infringement complaint and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all 13 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 13 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. The Court also questions whether Plaintiff has shown that the Court can exercise personal jurisdiction over the defendants. To adequately plead personal jurisdiction, Plaintiff must sufficiently allege that the defendants actually sold the allegedly infringing product to a customer in Illinois. See Liu v. Monthly, No. 25-2074, 2026 WL 880018, at *1 (7th Cir. Mar. 31, 2026) (citing Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020)). The complaint alleges sales in this district, but those allegations are conclusory, and Plaintiff did not provide proof of actual sales in this district. See id. (remanding with instructions to dismiss for lack of personal jurisdiction because plaintiff had not provided screenshot evidence of actual sales in Illinois). Additionally, Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the names of defendants or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightsholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", 794 F. Supp. 3d 543, 552 (N.D. Ill. 2025). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject of the case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-568 (7th Cir. 2000). Plaintiff also did not file a motion to seal those documents. Similarly, Plaintiff submitted two declarations [8][9] wherein the declarants assert that Plaintiff requires a temporary restraining order, but Plaintiff has not moved for such relief. Counsel is admonished to review and comply with all court procedures and applicable rules. The Clerk of Court is directed to unseal the documents filed at [2] [10]. By 4/21/26, Plaintiff must file either a memorandum explaining why joinder and personal jurisdiction are proper, or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity and grounds for personal jurisdiction. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Plaintiff's motion for electronic service of process [13] and motion for issuance of summons [14] are denied without prejudice. Mailed notice (gel,)