2024-cv-03068

COMPLAINT filed by Bulgari, S.p.A.; Filing fee $ 405, receipt number AILNDC-21864802.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Schedule A regarding complaint[1]

MOTION by Plaintiff Bulgari, S.p.A. for leave to file under Seal

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bulgari, S.p.A.

Notice of Claims involving Trademarks by Bulgari, S.p.A.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Andrew Daniel Burnham

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Luana Faria De Souza (Faria De Souza, Luana)

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 Plaintiff Bulgari, S.p.A. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Bulgari, S.p.A. in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Laurence Morel-Chevillet regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Bulgari, S.p.A. Exhibit 5 Parts 1-4 regarding declaration[17]

MOTION by Plaintiff Bulgari, S.p.A. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Bulgari, S.p.A. in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte Telephone conference held on 4/24/2024. Transcript is to remain sealed. Motion for temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery [14] is granted. Enter Temporary Restraining Order. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] is granted. Mailed notice. (jn,)

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 4/25/2024. Mailed notice.

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

Registry Deposit Information Form by Bulgari, S.p.A.

BOND in the amount of $ 78,000 check, Receipt No.100005709, posted by Bulgari, S.p.A.

MOTION by Plaintiff Bulgari, S.p.A. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Bulgari, S.p.A. in support of motion for preliminary injunction[25]

Declaration of Andrew D. Burnham

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [25] is set for 5/9/2024 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/6/2024, answer due 5/27/2024.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiff Bulgari, S.p.A. by Quinn Bradley Guillermo

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/9/2024. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 25 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibit 5 to the Declaration of Laurence Morel-Chevillet 18, and the TRO 23. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 6/11/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

NEW PARTIES: Dongguan Viya Jewelry Co., Ltd., Guangzhou Haolin Ornaments Co., Ltd., Guangzhou Qiku Trading Co., Ltd., Guangzhou Zhuodie Jewelry Co., Ltd., Haifeng TODERI jewelry factory, Haifeng Youmili Jewelry Co., Ltd., Sincere Trader Leather Goods Co., Ltd., Yiwu Sandong E-Commerce Co., Ltd., Italia Gioielli Store, Miana Jewelry Store, xununu, yongxiangsui store, Bags1227, ckxs, cuel, d1wt, d2cj, dacjewelry01, dede5, Designer bag123, designer_bags8899, designerbag8886, designerbagshoes6, dtcs, ecbs, efbe, egqv, ewjyy, f9uo, fashionbag_168, fbxf, fzcvape, gordon958, governor011, henryjewelrys, huizi888, ibezo, j1gz, jessieus, jewelrywholesal, jursn968, k9qq, kl4z, luxurys_handbags0, lyouyig4, meilila, njiz, omky, pedmg, qqfp, raeo, rogd, sije_store, smxx, trendy_bags, u8be, versatile_bags, vilz, vnom, vzfz, wldl, womensbags4, wzgtd, xjguk, xmos, zpfx, guowei-981, lojia59, qiasihanguang40, qiaun-bai, yangxiaoting886, yaoda61, yuhl12, Aimaibag, Fast fashion womens bag, XWX Jewelry, topbag612 and uswatches.me added to case caption.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 5/9/2024. Mailed notice.

SUMMONS Returned Executed by Bulgari, S.p.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/23/2024, answer due 6/13/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

NOTICE of Voluntary Dismissal by Bulgari, S.p.A. as to certain defendant

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 6/11/2024. A telephone status hearing is set for 7/11/2024 at 9:00 a.m., unless a hearing on a motion for default is scheduled before then. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

MOTION by Plaintiff Bulgari, S.p.A. for entry of default, MOTION by Plaintiff Bulgari, S.p.A. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Bulgari, S.p.A. 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 Thomas M. Durkin: The status hearing set for 7/11/2024 is vacated. A telephone hearing as to the motion for entry of default and for default judgment is set for 6/25/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Plaintiff Bulgari, S.p.A. by Berel Yonathan Lakovitsky

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 6/25/2024. No one appeared on behalf of defendants. Motion for entry of default and default judgment 35 is granted. Civil case terminated. Mailed notice.

DEFAULT Judgment Order. Signed by the Honorable Thomas M. Durkin on 6/25/2024. Mailed notice.