2024-cv-04991

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-22149280.

Exhibit 1

Exhibit 2

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Exhibit 4

Exhibit 5

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 Rachel S Miller

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MOTION by Plaintiff Chrome Hearts 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 Chrome Hearts LLC in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Mario Lejtman regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1-8 regarding declaration[15]

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]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[17], motion for leave to file[3], motion for temporary restraining order[12] before Honorable Manish S. Shah on 6/25/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [12] [17] are granted, and no appearance 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.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Manish S. Shah on 6/24/2024.

Registry Deposit Information Form by Chrome Hearts LLC

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

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[24]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[25]

NOTICE of Motion by Rachel S Miller for presentment of extension of time[24] before Honorable Manish S. Shah on 7/3/2024 at 09:45 AM.

SURETY BOND in the amount of $ 50,000.00 posted by Chrome Hearts LLC

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 24 is granted, and no appearance is necessary. The TRO is extended to 7/22/24. Notices Mailed.

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[30]

Declaration Of Rachel S. Miller

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[30] before Honorable Manish S. Shah on 7/18/2024 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 7/15/2024, answer due 8/5/2024.

Declaration of Rachel S. Miller

Exhibit A

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [30] 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 7/18/2024. Notices Mailed.

NEW PARTIES: Dongguan Aizhilin Eco-Friendly Metal Products Co., Ltd., Dongguan Dazzling Jewelry Co., Ltd., Dongguan Shinywin Cosmetic Technology Co., Ltd., Foshan Old Jewelry Wolf Jewelry Factory, Foshan Yu Jun Jewelry Company Limited, GUANGDONG DG JEWELRY CO.LTD, Ningbo Sunkin Electrical Co., Ltd., Shenzhen Atila Jewelry Co., Ltd., Shenzhen Suoleikesi Technology Co., Ltd., Sichuan Chendang Technology Co., Ltd., Suzhou Juanran International Trade Co., Ltd., Yiwu Beiya Jewelry Co., Ltd., Yiwu Chongke Electronic Commerce Co., Ltd., Yiwu Dumond Cosmetics Co., Ltd., Yiwu Guohe Jewelry Co., Ltd., Yiwu Hebi E-Commerce Firm, Yiwu Kingme Jewelry Co., Ltd., Yiwu Miaoyi Jewelry Factory, Yiwu Nuojin Trading Co., Ltd., Yiwu Shengwang Trading Co., Ltd., Yiwu Shuohui Trading Co., Ltd., Yiwu Xierrui Trading Co., Ltd., Yiwu Yizhi Trading Company Limited, A11MXZEBC746K0, A2ZR1QGAGCJITM, A3E4TSXXBBQHTM, aayouli, AB9CJOELVY5AK, AX35CHWFUMJF7, Beginow, cailianhao, Chen9926, chengbaohuadianzishangwu, Cool-Hearts, djdiu1hji-us, DuiHuoShangMaoYouXianGongSi, ezhoushinuojiatushangmaoyouxiangongsi, Fensd USA, Haipeig, HAOTIANDADA1, huihuangshangmaogongsi, jianjizhouquxiaonizikuajingdianshangyouxiangongsi, KEXU store, KunMingRongShenShangMaoYouXianGongSi, lichanghongbaihuoshanghang, NAIYING, onyes, QinHuangDaoMoXiaoYunWenHuaChuanBoYouXianGongSi, qinzhengyang store, Ruihua Lucky Store, runankongcanzhuanyedian, ShaiSaiBaiHuo, shaohuadeshangdian, shenhanmeiguo, Smile is free, tingbodianpu, tongshanxiantaowamaoyiyouxiangongsi, wangqikunshop, WenJiE, WHSW, wuhanshiyiguangyikemaoyouxiangongsi, wyf06242350xmh, Xiaoaoao Stroe, yangdaoushangmao, yangsa store, yarudianzishangwuhezeshicaoxianyouxiangongsi, Zamize, zay amz, ZhiJiangShiBuBiShangMaoYouXianGongSi, zhuaidedian, amhats, bald_eagle, bamolalaer, buychromescloth, fashion018, kittyshaw2019, mcf88442, xiezong08, abholos, chetan--0, dtsrr_rdt, gill_ida, hami_ltion, pengp-2183, zhu5258, celina_twg, gdaset2018, guoeskmx1123, Ms Z lady jewelry, ZXLXR, ninjahype.co, reedoonframes.com, woodbuyoutlets.com, chromeheartclothing.com, chromeheartshirt.com and altavanstore.com added to case caption.

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendant

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Luana Faria De Souza (Faria De Souza, Luana)

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

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[40]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[41]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment[40] before Honorable Manish S. Shah on 8/13/2024 at 09:45 AM.

Exhibit A

NOTICE of Voluntary Dismissal by Chrome Hearts LLC as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: No appearance on 8/13/24 is necessary. Any objections to the motion for default judgment must be properly filed by 8/13/24. If no objections are filed the motion will be considered unopposed, and the court will rule by cm/ecf. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: No objections to the motion for entry of default judgment have been filed. The motion is unopposed and granted. The court, after weighing the relevant factors for statutory damages, concludes that $10,000 is an appropriate award. Enter default judgment and terminate civil case. Notices Mailed.

FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 8/15/2024. Notices Mailed.

FULL SATISFACTION of Judgment regarding order 47 in the amount of $10,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 47 in the amount of $10,000 as to certain defendant

NOTICE of Removal of Material from the Custody of the Clerk's Office: Doc. # 29 Surety Bond in the amount of $50,000.00 by John Summerfield, Greer, Burns & Crain, Ltd. (Received by Intake Counter on 10/29/24).