2024-cv-01801

COMPLAINT filed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC; Filing fee $ 405, receipt number AILNDC-21702922.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Schedule A regarding complaint[1]

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC

Notice of Claims Involving Trademarks by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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 Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Nicolas Lambert regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Exhibit 3 - Parts 1-10 regarding declaration[14]

SEALED EXHIBIT by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC Exhibit 3 - Parts 11-12 regarding declaration[14]

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[11], motion for leave to file[3], motion for miscellaneous relief[17] before Honorable Manish S. Shah on 3/12/2024 at 09:45 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [11] [17] are granted, and no appearance on the motions is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 3/7/2024. Notices mailed.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A.

SURETY BOND in the amount of $ 50,000 posted by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC (Document not scanned.)

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for preliminary injunction[26]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[26] before Honorable Manish S. Shah on 3/21/2024 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2024, answer due 4/8/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 26 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 3/21/2024. Notices mailed.

NEW PARTIES: MMAORUI, MMcute190, Msstoodun, NLAFJKJ-783knw, PANDACLOUD, Peak V, Peng Zikang, pingdingshanshilelingshangmaoyouxiangongsi, Qin-hs, rongyuheng, SaiDiAn, Shanghai Musong, shangqinsenshangmao, Shanxi Duohonghongyu Shangmao Youxiangongsi, ShiJinQiang226, SHINE-SHOP, shixiaoying001, Sister jewelry, Skyline Treasures, Song zhenxing, Starry Night1, taianshihongsidianzishangmaoyouxiangongsi, TianDuanShangMao, TiaoTiaoXiaoPu, Tophill trading, TRAVISTAR-US, Trust me and satisfy you, Uncle Sam house, vfuvhu, VIEOAGEO, VITALWELL SHT, Voidous, WANG XIANG DONG, wangmingtengshangmao, WITATAOGE, WOG2008, wudinvzhuang, wuhouenngsjdianp, wuhushixiaohuanshangmaoyouxiangongsi, wuhushizhengkunshangmaoyouxiangongsi11, Wumin shop, wxt shop, XAYP, XiaoKaFei, xiapuxianduoqianshangmaoyouxiangongs, XiBinBaiHuo, XiQiBaby, xuchang126, xuchangshiweidouqucaiweibaihuodian, xudongxiao, YANGHENG, yangyunfeidian, yanyanbodexiaodian, Yi ran mao yi, yiyijinUS, Yuanxiu, yueqiangshangmaogufen, YUNBO Premium Store, zhang dan dian, zhangjunru, zhangqinshangwu, zhexiyan457, ziyibaobao, ZXG shop, baobagshop, baobagshop01, here_is_wholesaler1, luxury_lady_bag, quality_bags, serendipity_bags, top_designers, xiaoshumiao2017, yunxin1995, yyds2020, certified-authentic-products650, jingmo-46, liancxdydzi, senecaimpacta_0, gloriatoo88, laimei667, shoe.supplier.china, CP Watch Shop, Zhen charm watch franchise and bagshome10 added to case caption.

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to Certain Defendants

MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for entry of default, MOTION by Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for entry of default, motion for default judgment, 36

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 37

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, 36 before Honorable Manish S. Shah on 4/23/2024 at 09:45 AM.

(Exhibit A)

NOTICE of Voluntary Dismissal by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC as to certain defendants

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Andrew Daniel Burnham

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Luana Faria De Souza (Faria De Souza, Luana)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment [36] is granted. Enter default judgment order. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 4/23/2024. Notices Mailed.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 44 in the amount of $50,000 as to certain defendant

***Civil Case Terminated.

FULL SATISFACTION of Judgment regarding order[44] in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 44 in the amount of $50,000 as to certain defendant