2024-cv-08809

COMPLAINT filed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC; Filing fee $ 405, receipt number AILNDC-22514641.

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

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 Transfer of the Defendant Domain Names, 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 - 3 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[16]

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

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for miscellaneous relief[16], motion for temporary restraining order, [11] before Honorable Jeremy C. Daniel on 10/1/2024 at 09:30 AM.

ATTORNEY Appearance for Plaintiffs Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. The plaintiff's motions for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11] and motion for electronic service of process pursuant to FED.R.CIV.P. 4(f)(3) [16] are granted. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 10/1/2024. Mailed notice.

Registry Deposit Information Form by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC

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

SURETY BOND in the amount of $ 10,000.00 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 as to Certain Defendants

Exhibit A

MEMORANDUM by Marc Jacobs International, LLC, Marc Jacobs Trademarks, LLC in support of motion for preliminary injunction[25]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[25] before Honorable Jeremy C. Daniel on 10/15/2024 at 09:30 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 10/9/2024, answer due 10/30/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Jeremy C. Daniel: The motion hearing scheduled for October 15, 2024, is continued to October 22, 2024, at 9:30 a.m. The temporary restraining order 22 is extended until October 23, 2024, to allow the Court to hear the plaintiff's motion for a preliminary injunction. The plaintiff shall provide notice of this change to all defendants. Mailed notice.

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

SUMMONS Returned Executed by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/18/2024, answer due 11/8/2024.

Declaration of Quinn B. Guillermo

Exhibit A

ATTORNEY Appearance for Plaintiffs Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC by Justin Tyler Joseph

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 10/22/2024. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction as to certain defendants 25 is granted. The plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on court's website located at www.ilnd.uscourts.gov/instructions. Mailed notice.

NEW PARTIES: DONGGUAN BAICAIHUI WEBBING LTD, Dongguan Yinuo E-Commerce Co., Ltd., Guangzhou Hua Cheng Hardware Co., Ltd., Guangzhou Nice Metal Products Co., Ltd., Guangzhou United Honour Enterprises Ltd., Yiwu Canqing Commodity Film, Yiwu Fu Tang E-Commerce Firm, Yiwu Jiaze Luggage Co., Ltd., Yiwu Pinxun Trading Co., Ltd., Yiwu Reliant Trading Company Limited, A1LVYQ1XNN8H5O, A1WRUSJ5A760B6, A3FR3X3YYPX34V, A3JKBM5ISBMZFH, A3L9GJ43V4GKXX, ABYGREVFNC5Q6, aiguangshangmaodian, Alonggoods, anhuitongqi, BaiBaiWan, BanShangTaoSMH, BCZ Shop, BENKA, BYKOINE-US, Cat'sHouse-lyx, ChangFengDZ, ChaoShenG, chenshunwenhua, chenzhi-us, dachengyanxuan, Dan Qing American direct store, DuanBaI, ESHANGFASHION, Eternity Z, ezhoushiqihonghangbaihuoshanghanggerenduzi, fengyia, ffdian, Flying Rainbow1, Furniture and Supplies Store, guijiangshangwushe, hefeibeijundianzishangwushanghang, heyongcan, huainanwangbaodianzishangwuyouxianzerengongsi, HuangZhiDianZiShangWuYouXianZeRenGongSi, huihuimin, HuISheNg, HuZhiXZH, huzichundexiaodian, Integrity Shop1, jianyingbaihuo, jie mei ruo xian, JingChuanBLD, jingmengshangmao, JingYu8, JuSi, juxin-US, JXNDD, kuangsibaihuoshanghang, kunpengwenhua, lihujiaju, LinYaDZ, LiuFengDianZiShangWuYouXianZeRenGongSi, LJKDDD, ljnDD, LuxsHabitat, MinYiKY, morning glow, NanBinYang, OEIPSMK-CH, OUYANG1, OuZhuan, QSDSTOR, Refined glory, RenJiaCheng0203, RORIOS-USA, shi yu shang mao, ShuangWenJia, shulideshop, sijijiayuanmaoyiyouxiangongsi, SRC co.,Ltd, sunlitongmeiguo, taiyuanshihefeiyangshangmaoyouxiangongsi, taiyuanshisunyinchaoshangmaoyouxiangongsi, take a clear-cut stand, Tengrou bag, wangchennb, wangli12, wangshangbaihuoshanghang, WKPST, WRTXYUIYP, xiaosanmaoyi, xie xue qin, XinJiaLi, XinLii, YFMMAD, Yiming Fashion Creative Store, YingQiaN, yiwuyingbai, yongjilimeibaihuoshanghang, yuangyoushangmaoyouxiangongsi, YuQiBHD, Yushengdianzishangwufuwuyouxiangongsi, zaozhuangyuelindianzishangwuyouxiangongsi, ZCLSTORE, ZEPINGSHOP, ZhangJiaJunDianZiShangWuYouXianZeRenGongSi, zhanguangbang, zhangwei-XLLLLL, ZhenSonG, Zhongshan Anlinya Trading Co. Ltd, ZhuYunBG, ZiChunBH, flowers__yyy57, guccilvslyy, Quadratic square, DenzQ, GuangDongShengKangDiChongQiWanJuYouXianGongSi, SikaFu, Tonymei, Totebag, weiwei, marcjacobsoutletusa.com and marcjacobsfactoryoutlets.com added to case caption.

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

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

(Exhibit A)

MEMORANDUM by Marc Jacobs Trademarks, LLC, Marc Jacobs International, 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)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, 35 before Honorable Jeremy C. Daniel on 11/19/2024 at 09:30 AM.

(Exhibit A)

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 11/19/2024. Plaintiff's motion for entry of default and default judgment as to all remaining defendants [35] is granted. Signed by the Honorable Jeremy C. Daniel on 11/19/2024. Civil case terminated. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case, 39 in the amount of $50,000 as to certain defendants

MINUTE entry before the Honorable Jeremy C. Daniel: Status report due on or before by 12/13/2024. Mailed notice.

STATUS Report Pursuant to 42 by Marc Jacobs Trademarks, LLC, Marc Jacobs International, LLC

MINUTE entry before the Honorable Jeremy C. Daniel: This case is now closed. See R. 43. Civil case terminated. Mailed notice.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case, 39 in the amount of $50,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case, 39 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, motion hearing, terminated case, [39] in the amount of $50,000 as to certain defendant