2025-cv-06079

COMPLAINT filed by Collegiate Licensing Company, LLC; Filing fee $ 405, receipt number AILNDC-23558637.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Collegiate Licensing Company, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collegiate Licensing Company, LLC

Notice of Claims Involving Trademarks by Collegiate Licensing Company, LLC

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Allyson M. Martin

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

NEW PARTIES: 2024 FAST Clearance SALE, A1A3D6QYMIMOHI, A32XVZVNUFBKYP, Ainguu Art, BalanarNeon, Bellelement, Changzhou Xuyongliang Optical Technology Co., Ltd., ChenJ_DIY, chongyangxianyizhihedianzikejiyouxiangongsi, coco-DIY, dongyu clo, DZSHJBH, fengshu-US, FIRSTROAD, flwlyyf, Guangzhou Bayu Clothing Co., Ltd., cartier_necklace, chanel_pt, abigail_terlandu, aidenher5, akfillin06, angxiuzhuangsh, arlette_csusson, as_854385, b-805693, bigplayerstec-0, bingdiao-4, bobbcy_ross, brun_hanney, cangzhong-61, canruo3, cary_grindle, cefi_50, chengban, chudou5, ciliu1241, daisy_grooms, duangai, duk63l-0, et_37528, frederick_hmkenderson, gapiao4, AGGOOSHOP, AMOXIHFA, ApparelAlley, Audacious Fashion Styles, Avantgarde Attire Apparel, Baishur, Bakubaku, BANBO ULTRA SENSE, Beautiful young trend, Bene ony local, Bernese, Best Tshort, Black Fast Fashion, BLADD, Blanket flying to the sky, Blossom Avenue, BoldBespoke, Boutique Style Wardrobe, BSAMUELXFD, CAALEB, CAEDMON, CAIXUKUN, CAMELLIACBF, Casesisters, Cfchaowu, CGYRT, CHABXI, changwansg, Chic Corner chen, ChicBoutiques, ChicGrace, Classic Charm, ClassicCult, clothinshop, CMSJ TRADE, Conisi, conisi ChicTQueen, consists, CooMan, COZY STREET KINGS, Crane Mens clothing, CrazyBabyc, CrazyLadyG, CrazyMum, CuddleSocks, Current information, CustomTeeCo, Cypress BJ, DAO DAO TWO, Diy A Boutique, DIY A Fashioner, DIY TShirt local, DMIR, DOGESHOP, DONOTTAGS, E Boutique Bliss, Easy HB, Efashions, Eisenshop, Elegant Ensemble, Ember Lace, EMILYXFF, Eminence Threads Fashion local, Fashion Leeugurs, FitGoddess, fodk, Freedom look, ggjhh, GlamorFusion, HAPPY GO TO YOU, ABBNHK, Allreen & Sfneewho, bowen2658, CENOYEE, CHIEU NGA LTD, CONG TY TNHH DU LICH DICH VU THUONG MAI VAN TUONG, dgterdafmme, DTP Fashion Mall and Fashion Innovation Store added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Collegiate Licensing Company, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Lindsay Conn regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Exhibit 1 - Parts 1-2 regarding declaration[16]

DECLARATION of Sterling Hawkins regarding memorandum in support of motion[14]

Exhibit 1

MOTION by Plaintiff Collegiate Licensing Company, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for miscellaneous relief[19]

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

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[13], motion for miscellaneous relief[19] before Honorable Manish S. Shah on 6/12/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 6/12/25 is necessary. The ex parte motions [3], [13], and [19] are taken under advisement. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions are granted. Enter Sealed TRO. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 6/16/2025. Notices Mailed.

Registry Deposit Information Form by Collegiate Licensing Company, LLC

SUMMONS Submitted (Court Participant) for defendant(s) 2024 FAST Clearance SALE and all other Defendants identified in the Complaint by Plaintiff Collegiate Licensing Company, LLC

SUMMONS Issued (Court Participant) as to Defendant 2024 FAST Clearance SALE and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 50,000.00 posted by Collegiate Licensing Company, LLC

MOTION by Plaintiff Collegiate Licensing Company, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Collegiate Licensing Company, LLC in support of extension of time 29

DECLARATION of Allyson M. Martin regarding memorandum in support of motion[30]

NOTICE of Motion by Allyson M. Martin for presentment of extension of time[29] before Honorable Manish S. Shah on 6/26/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 29 is granted, and no appearance is necessary. The TRO is extended to 7/14/25. Notices Mailed.

MOTION by Plaintiff Collegiate Licensing Company, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for preliminary injunction[35]

Declaration of Allyson M. Martin

NOTICE of Motion by Allyson M. Martin for presentment of motion for preliminary injunction[35] before Honorable Manish S. Shah on 7/10/2025 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Collegiate Licensing Company, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/7/2025, answer due 7/28/2025.

Declaration of Rachel S. Miller

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [35] 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 7/11/2025. Notices Mailed.

ATTORNEY Appearance for Defendant Bellelement by Christopher Paul Keleher

MOTION by Defendant Bellelement for extension of time to file answer regarding complaint[1] (UNKNOWN IF OPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer[42] before Honorable Manish S. Shah on 8/6/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Defendant does not appear. With no objection from plaintiff, the motion for extension of time [42] is granted. Defendant Bellelement must respond to the complaint by 8/18/26. Notices mailed.

MOTION by Plaintiff Collegiate Licensing Company, LLC to approve consent judgment as to Certain Defendants

Exhibit A

MOTION by Plaintiff Collegiate Licensing Company, LLC for entry of default as to all Remaining Defendants, MOTION by Plaintiff Collegiate Licensing Company, LLC for default judgment as to all Remaining Defendants

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for entry of default, motion for default judgment, [46]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[47]

Exhibit 1

NOTICE of Motion by Allyson M. Martin for presentment of motion to approve consent judgment[45], motion for entry of default, motion for default judgment, [46] before Honorable Manish S. Shah on 9/2/2025 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendants ChicGrace, FitGoddess, GlamorFusion by Xuanjie Wang

MOTION by Defendants ChicGrace, FitGoddess, GlamorFusion for extension of time to file answer regarding complaint[1]

NOTICE of Motion by Xuanjie Wang for presentment of motion for extension of time to file answer[51] before Honorable Manish S. Shah on 9/2/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing on 9/2/25 at 9:45 a.m. will proceed via telephone. Parties to the case, members of the public, and the media, may participate in/listen to these proceedings by dialing 1-650-479-3207 and using access code 2302 545 7949. 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. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing on 9/2/25 is reset to 10:15 a.m. and will proceed via telephone. Parties to the case, members of the public, and the media, may participate in/listen to these proceedings by dialing 1-650-479-3207 and using access code 2302 545 7949. 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. Notices Mailed.

ATTORNEY Appearance for Defendants ChicGrace, FitGoddess, GlamorFusion by Christopher James Fahy

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Manish S. Shah: For the reasons stated in open court, the motion for extension of time [51] is granted. Defendants ChicGrace, FitGoddess, and GlamorFusion must respond to the complaint by 9/15/25. The motions to approve the consent judgment [45] and entry of an order of default judgment [46] are granted. Enter Orders. The remaining parties shall file a status report with a proposed case schedule by 9/22/25. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 9/2/2025. Notices Mailed.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 9/2/2025. Notices Mailed.

MAILED trademark report with certified copy of minute order dated 9/2/25 to Patent Trademark Office, Alexandria VA

MOTION by Defendants FitGoddess, GlamorFusion, ChicGrace to dismiss

MEMORANDUM by ChicGrace, FitGoddess, GlamorFusion in support of motion to dismiss[61]

Declaration Huang

Declaration Liao

Declaration Zhu

NOTICE of Motion by Christopher James Fahy for presentment of motion to dismiss[61] before Honorable Manish S. Shah on 9/18/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 9/18/25 is necessary. Plaintiff shall respond to the motion to dismiss by 10/7/25 and defendants may reply by 10/21/25. The court will rule by cm/ecf. The court vacates it order authorizing early, expedited discovery between plaintiff and defendants No. 107 FitGoddess, No. 111 GlamorFusion, and No. 73 ChicGrace. The parties' proposed case schedule remains due 9/22/25. Notices Mailed.

FULL SATISFACTION of Judgment regarding order[58] in the amount of $50,000 as to certain defendants

STATUS Report Joint per [57] by Collegiate Licensing Company, LLC

MINUTE entry before the Honorable Manish S. Shah: All discovery must be noticed in time for completion by 4/24/26. The court will set dispositive motion deadlines when the parties get closer to completing discovery. The parties shall file a joint status report on discovery progress by 12/17/25. Notices mailed.