2024-cv-09199

COMPLAINT filed by Celine SA; Filing fee $ 405, receipt number AILNDC-22539456.

Exhibit 1 - Trademark Registrations

Exhibit 2 - 2021 Customs IP Seizures

Exhibit 3 - Chow article

(Exhibit 4 - Homeland Sec 2020 Report)

SEALED EXHIBIT by Plaintiff Celine SA

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Celine SA by John B Haarlow, Jr

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Celine SA

MOTION by Plaintiff Celine SA to seal

Notification of Claims Involving Trademarks by Celine SA

MAILED Trademark report to Patent Trademark Office, Alexandria VA

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category Two).

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.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. If the template is not completed by October 16, 2024, the Court may dismiss this matter for failure to prosecute. Mailed notice.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

SEALED EXHIBIT by Plaintiff Celine SA Schedule A Template

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

(Exhibit)

MOTION by Plaintiff Celine SA for temporary restraining order

MEMORANDUM by Celine SA in support of motion for temporary restraining order 12

DECLARATION of Nicolas Lambert

(Exhibit 1 - Trademark Registrations)

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

SEALED EXHIBIT by Plaintiff Celine SA

DECLARATION of John Haarlow

Exhibit 2021 Customs IPR Seizure Stats

Exhibit GIPC article

Exhibit Economic Impact report

(Exhibit Unpublished Decisions)

MOTION by Plaintiff Celine SAService via electronic means

MEMORANDUM by Celine SA in support of motion for miscellaneous relief 23

DECLARATION of John Haarlow

Exhibit Hague Convention

(Exhibit Unpublished Orders)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff is to submit a proposed temporary restraining order to the Courts PO Box by October 16, 2024. Mailed notice.

MOTION by Plaintiff Celine SAExtend TRO

DECLARATION of John Haarlow regarding motion for miscellaneous relief 30

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion to extend the TRO 30 is granted. The TRO is extended to November 12, 2024. Mailed notice.

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

MOTION by Plaintiff Celine SA for preliminary injunction

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [33] for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by November 4, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 33 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 37 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Mercer Oak LLC. is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

NEW PARTIES: ankuf, dongmingdexiaodain, hilion, huaboshang, Man Feimao, Promise Boutique, quanzhouxucai, Sammiway, ShiChun, SSHH-001, Suiwesey US, tarcy997, XZFYSMYXGS, YuyingYouxuan, ZipLining, Defendant 016 as identified on Sch A, ablulu526, adornedechoes, belts8886, brandfactory16, Canadian Goose Jacket Doudoune, cartiglasses, chaochao11, Cino bag World, clothesbags77, comfortshoe, copy_center2, designer belt 1, designer factory, designerbag, dhgatejpmax, dhtyler168, Factory specialty brand, fairestoffair, fashion_ker, fashion52088, fashionablebelt, hatrendy, hottfactory, ilovemeganfox, leeshine, Luxury Sunglasses, luxurystore66, mnvmnv6, nicebag1, PPDA926, ppdda1990, qifei09, qpw_trend_shop6, qualitybelts, shubiaodian1677, sonicehat, sunglass08, sunglasses_ray2023, sunglasses_world, sunglasses23715, sunglasses86, SuperBagDesigner, topcargo, TT sunglasses wholesale, weote, westshoess, xsongstore and ysongbag added to case caption.

NOTICE of Voluntary Dismissal by Celine SA

MINUTE entry before the Honorable Lindsay C. Jenkins: By November 25, 2024, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

MOTION by Plaintiff Celine SA for default judgment as to all defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 42 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before December 4, 2024. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by December 2, 2024. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

DECLARATION of John Haarlow Service of Court Minute Order

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 42 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants (Plaintiff has failed to seek an accounting of profits), the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $100,000 is an appropriate award of statutory damages. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 12/4/2024. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 12/4/2024 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment Def 7