2024-cv-12272

COMPLAINT filed by Christian Dior Couture, S.A.; Filing fee $ 405, receipt number AILNDC-22780434.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Schedule A regarding complaint[1]

MOTION by Plaintiff Christian Dior Couture, S.A. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Christian Dior Couture, S.A.

Notice of Claims Involving Trademarks by Christian Dior Couture, S.A.

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Kahlia Roe Halpern

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Hannah Alexa Abes

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

MOTION by Plaintiff Christian Dior Couture, S.A. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for temporary restraining order[14]

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

DECLARATION of Nicolas Lambert regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Christian Dior Couture, S.A. Exhibit 5 - Parts 1-4 regarding declaration[17]

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

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for miscellaneous relief[19]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[14], motion for leave to file[3], motion for miscellaneous relief[19] before Honorable Charles P. Kocoras on 12/10/2024 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to seal 3, motion for entry of a temporary restraining order 14, and motion for electronic service of process 19 is granted. Presentment hearing on 12/10/2024 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 12/5/2024. Mailed notice.

Registry Deposit Information Form by Christian Dior Couture, S.A.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 10,000.00 posted by Christian Dior Couture, S.A.

MOTION by Plaintiff Christian Dior Couture, S.A. for extension of time of Temporary Restraining Order

MEMORANDUM by Christian Dior Couture, S.A. in support of extension of time[27]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[28]

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time[27] before Honorable Charles P. Kocoras on 12/19/2024 at 09:50 AM.

MOTION for Extension of Time of Temporary Restraining Order [27] is granted. The TRO is extended to 1/2/2025. Signed by the Honorable Charles P. Kocoras on 12/17/2024. Mailed notice. (jn,)

MOTION by Plaintiff Christian Dior Couture, S.A. for preliminary injunction

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for preliminary injunction[32]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[33]

SUMMONS Returned Executed by Christian Dior Couture, S.A. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/19/2024, answer due 1/9/2025.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for preliminary injunction [32] is granted. The Clerk is directed to unseal Schedule A to the Complaint [2], Exhibit 5 to the Declaration of Nicolas Lambert [18], and the TRO [24]. Plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three (3) business days. Instructions can be found at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice. (jn,)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 32 before Honorable Charles P. Kocoras on 12/31/2024 at 09:50 AM.

(Exhibit A)

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Charles P. Kocoras on 12/20/2024. Mailed notice. (jn,)

NEW PARTIES: Baoding Wei Wan Trade Co., Ltd., Dongguan City Rewin Gift Company Limited, Dongguan City Zonesin Gift Company Limited, Dongguan DG Jewelry Co., Ltd., Fujian Guanna Trading Co., Ltd., Fuzhou Kumi Silversmith Trading Co., Ltd., Gaoyou Baidi Garments Co., Ltd., Guangzhou Axili Tech Co., Ltd., Guangzhou Bssl Electronic Technology Co., Ltd., Guangzhou Changhui Leather Co., Ltd., Guangzhou Feifeng Trade Co., Ltd., Guangzhou Feitar Printing Co, Ltd., Guangzhou Hongchuang Glasses Co., Ltd., Guangzhou Teyi Luxury Clothing Co., Ltd, Guangzhou Xinmanli Trading Co., Ltd., GUANGZHOU YUANKUO ARTWARE CO.,LTD, Hangzhou Jiuran Luggage Co., Ltd, Huizhou Huicheng Lionorm Watch Strap Manufacturer, Market Union Co., Ltd., Ningbo Beilun Kunlan Tingshe E-Commerce Co., Ltd., Ningxia Yalumai Technology Co., Ltd., Qingdao Huayi Union Trading Co., Ltd., Quanzhou Huasong Information Technology Co., Ltd., Shaanxi Geogi Maer Network Technology Co., Ltd., Shanghai Mingchuan Xieshi Advertising Co., Ltd., Shantou Chaonan District Simapu Tiyouzi Trading Firm, Shenzhen Cainiao Leather Products Co., Ltd., Shenzhen Heibor Technology Co., Ltd., Shenzhen Huashengtai Electronics Co., Ltd., Shenzhen Momeishi Clothing Co., Ltd., Shenzhen Qihang Cross-Border Supply Chain Co., Ltd., Shenzhen Simai Trading Co., Ltd., Shenzhen Yunse Technology Co., Ltd., Xi'an Xi Ang Techonology Co., Ltd., Xiamen Juxin Huiyi Information Technology Co., Ltd., Xiamen Tongan District Billion Ricks Department Store(Individual Business), Yiwu Chanlian Garment Co., Ltd., Yiwu Hongjiu Trading Co., Ltd., Yiwu Ling Xi E-Commerce Co., Ltd, Yiwu Lvsa Jewelry Co., Ltd, Yiwu Real Care Trade Co.,LTD, Yiwu Xiangheng Packaging Co., Ltd., YUET SHUN INDUSTRIES LIMITED, Zaoqiang Pengze Leather Products Factory, chongqingnuoluosipumaoyiyouxiangongsi, DANCING ROCKETYWJ, efwgfe, kunmingyangedianzishangwuyouxiangongsi, LXTHTENG, QINHONGCHUAN, shenzhenshizhongshidadianshangyouxiangongsi, XNLALA, XuQiangBAIHUODIANBAOFU, XZSXFQJXMYYXGS, yihengwangluo, YJSHOP happy, china shoe store, tpzxe78, yangyong451, zhura7922, aureganedaeran_, breath6122, ddggr740, dolphin.221504, doniamoros, evandanyy, fhvhjbv7, guowei9923, jayden80929, likevipshops, louis13349, lverman6, mayiwawawa123, meili9429, top_luxury00001, wu_stockxxs72, yhq431, yolo_kickzz, zhangguoer51, ccee1202, bagfactory6632, diana.loves.to.sh, kqclnrsret8, luxurybagshop88, selin6730, bohuiguanggao, Coral Color Beauty, HuNanXinZhangGuiShangMaoYouXianGongSi, WS Dental, xiangyangdoujingshangmao, XYHWashop, zhuoyueguojimaoyi, gglvbag.ru, luxurious2.com, phyllisbages.com, tidelocker.top, youngrich.co, beautyofSong, BilingMall, chenzhens, cuirongrong1234, engqea1254, fanquan2134, fer6s5d6f2, Find Li, guapashops, guoqiguo01036, HEYUOPOP, Iris apple, liudingrong508, lshuangli, madadada, Marcos J Shock, matiantian4780, Monald, shadow.1, tuxi2671, tzqhachengyan, uftgjhfuyfy, wangdong2478, wangjiaxin3594, yangyshun5946, yuyang5645, zhengling1544, zzzhuhua and Lucyhandbag added to case caption. (Text entry; no document attached.)

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/20/2024: Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras:The hearing set on 12/31/24 for Plaintiff's motion for preliminary injunction is stricken. No appearance is required. Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: A status report is due on 1/30/2025. Mailed notice

NOTICE of Voluntary Dismissal by Christian Dior Couture, S.A. as to a certain Defendant

MOTION by Plaintiff Christian Dior Couture, S.A. for entry of default, MOTION by Plaintiff Christian Dior Couture, S.A. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Christian Dior Couture, S.A. in support of motion for entry of default, motion for default judgment[43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[43] before Honorable Charles P. Kocoras on 1/28/2025 at 09:50 AM.

Exhibit A

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for default judgment [43] is granted. Motion hearing set for 1/28/2025 is stricken. Civil case terminated. Enter default judgment order. Mailed notice

FINAL JUDGMENT ORDER signed by the Honorable Charles P. Kocoras on 1/21/2025. Mailed notice

EMAILED Trademark report with certified copy of minute order dated 1/21/25 to Patent Trademark Office, Alexandria VA

EMAILED Copyright report with certified copy of minute order dated 1/21/25 to Registrar, Washington DC

FULL SATISFACTION of Judgment regarding entered judgment 48 in the amount of $200,000 as to certain defendant

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Christian Dior Couture, S.A. to Amy Crout Ziegler at Greer, Burns & Crain, Ltd., 200 W Madison St, Ste. 2100, Chicago, IL 60606 via certified mail article # 9589 0710 5270 0579 7828 85. (Text entry; no document attached.)

RETURN of Service of MAILED original ten-thousand-dollar ($10,000) surety bond posted by Christian Dior Couture, S.A. to Amy Crout Ziegler at Greer, Burns & Crain, Ltd., 200 W Madison St, Ste. 2100, Chicago, IL 60606 via certified mail article # 9589 0710 5270 0579 7828 85 returned executed as to Amy Crout Ziegler.

FULL SATISFACTION of Judgment regarding entered judgment[48] in the amount of $200,000 as to certain defendant

ATTORNEY Appearance for Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District by Qin Zhuang

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District to intervene

Exhibit

Declaration of Junjun Wang

Exhibit

NOTICE of Motion by Qin Zhuang for presentment of motion to intervene[56] before Honorable Charles P. Kocoras on 8/19/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Motion to Intervene by Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District ("Kudi Watch Shop") [56] is granted. Kudi Watch Shop shall promptly file its proposed Motion to Enjoin or Reverse Asset Transfer, to Modify Asset Restraint, and to Vacate In Part or Otherwise Amend Default Judgment [56-1] as a separate docket entry. Plaintiff's response to the motion is due by 8/20/2025. Court will rule by mail. Presentment hearing scheduled on 8/19/2025 is stricken. Mailed notice.

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Jennifer Van Nacht

ATTORNEY Appearance for Plaintiff Christian Dior Couture, S.A. by Berel Yonathan Lakovitsky

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for extension of time to file MOTION TO ENJOIN OR REVERSE ASSET TRANSFER, TO MODIFY ASSET RESTRAINT, AND TO VACATE IN PART OR OTHERWISE AMEND FINAL JUDGMENT

MINUTE entry before the Honorable Charles P. Kocoras: Intervenor's motion for extension of time [61] is granted. Intervenor's motion is now due by 8/21/2025, and Plaintiff's response is now due 8/28/2025. Mailed notice.

MOTION by Plaintiff Christian Dior Couture, S.A. to stay regarding order on motion for extension of time, terminate deadlines, set motion and R&R deadlines/hearings, set deadlines[62]

DECLARATION of Justin R. Gaudio regarding motion to stay[63]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

NOTICE of Motion by Justin R. Gaudio for presentment of motion to stay[63] before Honorable Charles P. Kocoras on 8/26/2025 at 09:50 AM.

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District to set aside judgment MOTION TO ENJOIN OR REVERSE ASSET TRANSFER, TO MODIFY ASSET RESTRAINT, AND TO VACATE IN PART OR OTHERWISE AMEND DEFAULT JUDGMENT

Memorandum in Support of the Motion

Declaration supplemental declaration of Junjun Wang

Exhibit A-D

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion to Stay [63] is granted; the presentment hearing noticed for 8/26/2025 is stricken with no appearance necessary. Briefing on Intervenor's Motion to Enjoin or Reverse Asset Transfer, to Modify Asset Restraint, and to Vacate in Part or Otherwise Amend Default Judgment [66] is stayed pending further order of Court. The parties are granted until 10/21/2025 to conduct the relevant discovery. A telephonic status hearing is set for 10/21/2025 at 9:55 a.m. For the telephonic status hearing, parties are to use the following call-in number: 1-650-479-3207, access code 2300 000 6287 or with the following link https://us-courts.webex.com/meet/Judge_Kocorasilnd.uscourts.gov. When using the link, Counsel must type in their name when joining the call. Throughout the call, each speaker will be expected to identify themselves for the record before speaking. Mailed notice.

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for reconsideration regarding order on motion to stay, set deadlines, set/reset hearings, [67] MOTION TO RECONSIDER DISCOVERY ORDER OR, ALTERNATIVELY, FOR PROTECTIVE ORDER AND TO STAY DISCOVERY

Text of Proposed Order

NOTICE of Motion by Qin Zhuang for presentment of motion for reconsideration, [68] before Honorable Charles P. Kocoras on 9/2/2025 at 09:50 AM.

RESPONSE by Christian Dior Couture, S.A.in Opposition to MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for reconsideration regarding order on motion to stay, set deadlines, set/reset hearings, [67] MOTION TO RECONSIDER DISCOVERY ORDER OR, ALTERNATIVELY, FOR[68]

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District to withdraw motion for reconsideration, [68] NOTICE OF WITHDRAWAL OF MOTION TO RECONSIDER DISCOVERY ORDER OR, ALTERNATIVELY, FOR PROTECTIVE ORDER AND TO STAY DISCOVERY

MINUTE entry before the Honorable Charles P. Kocoras: Intervenor's motion to withdraw its motion for reconsideration [71] is granted. Intervenor's motion to reconsider discovery order or, alternatively, for a protective order and to stay discovery [68] is withdrawn. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: This matter is hereby referred to the Magistrate Judge for discovery supervision in connection with Intervenor's Motion to Enjoin or Reverse Asset Transfer, to Modify Asset Restraint, and to Vacate in Part or Otherwise Amend Default Judgment [66] and a settlement conference, if deemed appropriate. The Magistrate Judge has full authority to set and modify deadlines. Mailed notice.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Jeannice W. Appenteng for the purpose of holding proceedings related to: discovery supervision and settlement conference if appropriate. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: As a follow-up to the Court's referral order [73], the scope of the discovery sought by Plaintiff in connection with Intervenor's motion [66] shall be limited to only that which is intended to discover whether the Zelle address at issue evidences affiliation between Kudi Watch Shop and Youngrich.co. This should take no more than 30 days, although the Court leaves it to the Magistrate Judge's discretion whether that deadline needs to be extended. The parties are directed to file a joint status report regarding the discovery on 9/26/2025. Mailed notice.

MINUTE entry before the Honorable Jeannice W. Appenteng: This case has been referred for limited discovery supervision and settlement, if appropriate [73], [74]. The Court has reviewed the District Judge's recent order [75], which outlines the scope of discovery and sets a 9/27/2025 discovery deadline. By 9/5/2025, the parties shall file a joint status report setting forth what discovery has been completed, what discovery remains, whether the parties are interested in scheduling a settlement conference with the Court, and whether any discovery disputes require the Court's attention. Mailed notice.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District Amended Notification of Affiliates

STATUS Report Pursuant to 76 (Joint) by Christian Dior Couture, S.A. Presented before Magistrate Judge

MINUTE entry before the Honorable Jeannice W. Appenteng: The Court has reviewed the 9/5/2025 joint status report 78, which indicates that the parties are working through discovery and request additional time to serve discovery responses, serve subpoenas, and take any necessary depositions. The Court construes the request as a motion, which is granted. Discovery shall close on 10/30/2025. By 10/10/2025, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains, and whether any discovery disputes require the Court's attention. Mailed notice.

STATUS Report Pursuant to 75 (Joint) by Christian Dior Couture, S.A. Presented before District Judge

MOTION by Plaintiff Christian Dior Couture, S.A. to compel and Extend Discovery Presented before Magistrate Judge

DECLARATION of Jennifer V. Nacht regarding motion to compel[81]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

MINUTE entry before the Honorable Jeannice W. Appenteng: Plaintiff's motion to compel and extend discovery 81 is entered and continued. Telephone motion hearing is set for 10/15/2025 at 1:30 p.m. The call-in number for the hearing is 650-479-3207 and the access code is 2306 793 6027. Members of the public and media will be able to call in to listen to the hearing. 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

STATUS Report Pursuant to 79 by Christian Dior Couture, S.A. Presented before Magistrate Judge

RESPONSE by Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang Districtin Opposition to MOTION by Plaintiff Christian Dior Couture, S.A. to compel and Extend Discovery Presented before Magistrate Judge [81]

MEMORANDUM response in opposition to motion[85] by Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District

Declaration Xiyang WU

Exhibit B

Exhibit C

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for protective order Presented before Magistrate Judge

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for leave to file its response in opposition to Plaintiff's motion to compel (Dtk. 85) Presented before Magistrate Judge

MOTION by Intervenor Kudi Lebaoka Clock and Watch Shop, Xiamen Haichang District for leave to file Supplemental Local Rule 37.2 Certification Presented before Magistrate Judge

Supplement Supplemental Local Rule 37.2 Certification

Exhibit 1

MINUTE entry before the Honorable Jeannice W. Appenteng: Motion hearing held on 10/15/2025. For reasons stated on the record, plaintiff's motion to compel and extend discovery [81] is denied. Intervenor's motion for leave nunc pro tunc to file response to plaintiff's motion to compel and extend [88], motion for protective order [87], and motion for leave to file supplemental Local Rule 37.2 certification [89] are all denied as moot. By 10/22/2025, the parties shall meet and confer and file a joint status report indicating whether they have reached agreement on outstanding discovery disputes. If there is no agreement, plaintiff has leave to file its motion, which shall be due by 10/23/2025. Intervenor's response is due 10/28/2025. Telephonic status hearing is set for 10/30/2025 at 2:30 p.m. The call-in number for the hearing is (650) 479-3207 and the access code is 2306 793 6027. Members of the public and media will be able to call in to listen to the hearing. 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.

MINUTE entry before the Honorable Charles P. Kocoras: The telephonic status hearing before Judge Kocoras scheduled on 10/21/2025 is stricken with no appearance required. Mailed notice.