2024-cv-06629

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-22299896.

Exhibit 1

Exhibit 2

Exhibit 3

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 John J. Tharp, Jr. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 2).

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MAILED copyright report to Registrar, Washington DC.

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

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

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[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Mario Lejtman regarding declaration[18]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 5 - Parts 1-2 regarding declaration[19]

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[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff is required to supplement its TRO motion [16] with a listing of all prior on-line trademark/copyright infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff and a certification that it has not used any of the screenshot evidence supplied in support of a motion for TRO in any prior proceeding. Mailed notice

SUPPLEMENT to motion for temporary restraining order[16] per [24]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:An in-person hearing is set for 9:15 a.m. on Tuesday, August 13, 2024 in Courtroom 2303. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:In court hearing held as to this case and case 24-cv-6796. A further hearing will be set as appropriate. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, the plaintiff's motion for a temporary restraining order [16] is granted. The plaintiff's motions for leave to file under seal [3] and for electronic service of process [21] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 8/28/2024. Mailed notice

Registry Deposit Information Form by Chrome Hearts LLC

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

SURETY BOND in the amount of $ 89,000 posted by Chrome Hearts LLC. (Document not scanned)

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 32

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 33

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order 32 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 9/9/2024. Mailed notice

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

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction 38

Declaration of Trevor C. Talhami

(Exhibit 1)

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/20/2024, answer due 10/11/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [37], defendant nos. 61 and 78 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [38] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 9/25/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 9/23/2024. Mailed notice

NEW PARTIES: Dongguan Daha Jewelry Co., Ltd., Dongguan Fansen Jewelry Co., Ltd., Dongguan Five Stars Jewelry Co.,Ltd, Dongguan Jinyuan Jewelry Co., Ltd., Dongguan Joyful Jewelry Co., Ltd., Guangzhou Changjin Accessories Co., Ltd., Guangzhou Endless Jewelry Co., Limited, Guangzhou Hele Jewelry Co., Ltd., Haifeng Meilong Manbu Juzhi Jewelry Co., Ltd., Jiangxi Karong E-Commerce Co., Ltd., Kunshan Zhongrixin International Trade Co., Ltd., Shangrao Oriole Jewelry Co., Ltd., Shenzhen Junyuan Trading Co., Ltd., Shenzhen Mcgreen Technology Co., Ltd., Wuzhou Goldleaf Jewelry Co., Ltd., Wuzhou Redleaf Jewelry Co., Ltd., Xi'an Guozi Trading Co., Ltd., Yiwu Anyi Jewelry Factory, Yiwu Baiyou Jewelry Co.,ltd., Yiwu Changhe Trading Company Limited, Yiwu Juzhi Jewelry Co., Ltd., Yiwu Lucia Jewelry Co., Ltd., Yiwu Mi Ao Import And Export Co., Ltd., Yiwu Shangjie Jewelry Co., Ltd., Yiwu Sunrain Trading Co., Ltd., Yiwu Yaokai Jewelry Co., Ltd., ZHEJIANG FENGHUAN PRODUCTS CO.,LTD, Zhejiang Xinqi Jewelry Co., Ltd., A1APND5O57JTHS, A2EH3T6RHLKDH0, A2J31ZAPVH1M1, A3HMOF02LXYMOF, A3LH7WIZ0O064I, AJunPa, AL77M86XNGL4Q, Anshel, Axckjyxgs, caipiaozhongwubaiwanla, CCJewelryStore, DIMONVIP, EVBAGLU, FXQDD, GEM-inside, guangzhouyuhaoshangmaoyouxiangongsi21, guilong shop, HaNguyenShopp, hanhaoyushopq, hengyuanjushangmao, Henry_A, Jingjings, jiujiudianzi, KL E-Commerce, Li's Boutique Department Store, LongXingJiaDianZi, Looooxyo, miaomiaodeshangdian, NaiKG, NestStyleHaven, Opine, pingdingrenleshangmaoyouxiangongsi, SHJDARF, Soft cotton, Susanna_Stores, SWZ-US, TaoLingSha, tianqi-us, tingzhidianzi, vu quang huong, Weibo Stroe, Weigf, wupeiyang store, xinyaoshangmaoGOGOGO, Xueqi, xun lei dian zi, yangyuezhimildshop226, yinghaodianzishangwu, atobao, mi415589store, shenzhenxh, Tony's Magical Shop, velina_kiky, Hola Beauty, Jinbao toys daily necessities, ZanGlasses, chromhearts.com, chromeheartsclothings.net and chromeheartsclothes.com added to case caption.

TRANSCRIPT OF PROCEEDINGS held on August 13, 2024 before the Honorable John J. Tharp, Jr. Court Reporter Contact Information: Jennifer Costales, CRR, RMR, CRC - jenny.uscra@yahoo.com. 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 10/16/2024. Redacted Transcript Deadline set for 10/28/2024. Release of Transcript Restriction set for 12/24/2024.

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 45, defendant nos. 9, 21, 24, and 43 are dismissed from this case. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 47, defendant nos. 48, 55, and 82 are dismissed from this case. Mailed notice

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[50]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[51]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [49], defendant no. 58 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [50] is taken under advisement. Any objections or responses are due by 10/25/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 10/17/24. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Chrome Hearts LLC regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 54

Exhibit A

(Exhibit B)(Faria De Souza, Luana)

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [56], defendant no. 12 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [50] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 11/1/2024. Mailed notice

MAILED copyright report with certified copy of order dated 11/1/2024 to Registrar, Washington DC.

MAILED trademark report with certified copy of the order dated 11/1/2024 to Patent Trademark Office, Alexandria VA.

NOTICE of withdrawal of bond 31 by John Summerfield obo Greer Burns & Crain Ltd

FULL SATISFACTION of Judgment regarding order[59] in the amount of $125,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Chrome Hearts LLC v. The Partnerships and Unincorporated Associations Identified on Schedule AUpon plaintiff's report of full satisfaction of judgment 63, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant No. 41. Mailed notice