2024-cv-01188

COMPLAINT filed by Calvin Klein Trademark Trust, Tommy Hilfiger Licensing LLC, Calvin Klein, Inc.; Filing fee $ 405, receipt number AILNDC-21629242.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC Schedule A regarding complaint, [1]

MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC

Notice of Claims Involving Trademarks by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(List of Trademarks ex 1)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC in support of motion for temporary restraining order, [13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Dawn Buonocore-Atlas regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC Exhibit 2 - Parts 1-6 regarding declaration[16]

MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 2/22/2024 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 2/22/2024. For the reasons stated on the record, Plaintiffs' motion for leave to file under seal 3 is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are entered and continued. Telephonic status hearing set for 3/7/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

TRANSCRIPT OF PROCEEDINGS held on February 22, 2024 before the Honorable Andrea R. Wood. Order Number: 48120. Court Reporter Contact Information: Brenda S. Varney, CSR, RMR, CRR, brenda_varney@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 3/19/2024. Redacted Transcript Deadline set for 3/29/2024. Release of Transcript Restriction set for 5/27/2024.

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Jennifer Van Nacht

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/7/2024. For the reasons stated on the record, Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are granted. Enter Sealed Temporary Restraining Order. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 3/7/2024 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 3/21/2024 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 3/7/2024.

SURETY BOND in the amount of $ 10,000 posted by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC (Document not scanned.)

MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for preliminary injunction

Exhibit A

MEMORANDUM by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC in support of motion for preliminary injunction[28]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Calvin Klein Trademark Trust, Tommy Hilfiger Licensing LLC, Calvin Klein, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2024, answer due 4/8/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/21/2024. Only Plaintiffs appeared. For the reasons stated on the record, Plaintiffs' motion for entry of a preliminary injunction [28] is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2], (2) Exhibit 2 - Parts 1-6 [17], and (3) the sealed temporary restraining order [26]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 5/1/2024 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 3/21/2024. Mailed notice

NEW PARTIES: A3BLNLNXHKGVR5, Huomeng, Lontimesd, rebehaolee, anyanstore, bapestar66, beok234, bernice_store, buydhgates88, castin, chaoliufushi168, chinastore05, chinastore09, chuchu22, chuchu33, cjy_premium, cjy_suit_store, clothing_xz004, clothing_xz014, clothing190, dhgatered, dhlindamai1, dhonce, fffxingc4, hlp004, justhis1, linxia1991, lulules, maxt33, mling8, theface, vipsalemax9, vlone0210, wallesvip, wubt1, wyl12, xqlulus, xurx11, yuanqishenlin2023, zxy0408, ocxn7983, 6.34418E+14, chuangmingji, Guangsheng Supply chain, Happy Boy Wardrobe, Juncheng y, LILYYUAN, Maggie Fashion ornaments, Meite Fashion, Ming ink, Minmin Danno clothing and, One More Love, Onlytu, RGZwangyanze, Ryo clothing customization, SHOPELS, Space Clouthing Co Ltd, Swan costume, TOOM, Tufang Small shop, Vigo Houseware, WEIFIRE, WeOneStar, Wind riding number, xiaoyuashopgo, ZHIMEI SHOP, offerteborsabag.com, slimfitjeans-sales.com, Wangztr, xumian20, calvinklein-istanbul.com, calvinklein-id.com, margaretmcnab.com, beautyclothingsalesshop.com, blackhandbag-shop.com, cardiganshoponline.com, coatgreek.com, boxershorts-store.com, damensales.com, hoodieenfr.com, newlingerieshop.com, outdoorclothesshop.com, shirtsgreek.com, shoulderbag-online.com, calvinkleinzaoutlet.com, lojatommyhilfigerbrasil.com, tommyhilfigerclearancesale.com, tommyhilfigercolombiabogota.com, tommy-hilfiger-japan.com, usatommyhilfigeroutlet.com, tommyhilfigerhu.com, tommyhilfigersouthafrica.com, tommyhilfigercanadaoutlet.com, tommyhilfigeroutletstore.com, tommyhilfigerchileoutlets.com, hilfigers-canada.com, tommyhilfiger-malaysia.com, tommyhilfiger.vip, southafricaza.top, shoptommy.top, hilfiger.us.com, tommyhilfiger-sale.com and sanabriaoscar.com added to case caption.

NOTICE of Voluntary Dismissal by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC as to certain defendants

NOTICE of Voluntary Dismissal by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC as to certain defendant

MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for entry of default, MOTION by Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC in support of motion for entry of default, motion for default judgment, 35

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 36

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for entry of default and default judgment [35] will be heard at the telephonic hearing set for 5/1/2024 at 10:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Plaintiffs Calvin Klein Trademark Trust, Calvin Klein, Inc., Tommy Hilfiger Licensing LLC by Kahlia Roe Halpern

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 5/1/2024. For the reasons stated on the record, Plaintiffs' motion for entry of default and default judgment [35] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 5/3/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order[41] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 41 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 41 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[41] in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[41] in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[41] in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[41] in the amount of $500,000 as to certain defendant