2025-cv-07339

COMPLAINT filed by Celine SA; Filing fee $ 405, receipt number AILNDC-23689947.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

(Exhibit 4 to the Complaint)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Celine SA by Paul Joseph Kossof

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Celine SA

Notice of Claims Involving Trademarks by Celine SA

Trademark Report by Celine SA

DECLARATION of Paul Kossof

Exhibit 1 to the Declaration of Paul Kossof

Exhibit 2 to the Declaration of Paul Kossof

(Exhibit 3 to the Declaration of Paul Kossof)

MOTION by Plaintiff Celine SA to seal Schedule A, Exhibit 2 to the Declaration of Nicolas Lambert, and Plaintiffs Memorandum Establishing That Joinder Is Proper

SEALED DOCUMENT by Plaintiff Celine SA Schedule A

DECLARATION of Nicolas Lambert

(Exhibit 1 to the Declaration of Nicolas Lambert)

SEALED DOCUMENT by Plaintiff Celine SA Exhibit 2 to the Declaration of Nicolas Lambert

SEALED DOCUMENT by Plaintiff Celine SA Plaintiff's Memorandum Establishing that Joinder is Proper

MOTION by Plaintiff Celine SAfor electronic service of process.

Supplement Memorandum in Support of Motion for Electronic Service

Declaration Declaration of Paul Kossof in Support of Motion for Electronic Service

Exhibit 1 to Declaration of Paul Kossof in Support of Motion for Electronic Service

(Exhibit 2 to Declaration of Paul Kossof in Support of Motion for Electronic Service)

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

MOTION by Plaintiff Celine SA for temporary restraining order

(Supplement Memorandum in Support of Motion for Temporary Restraining Order)

NOTICE of Motion by Paul Joseph Kossof for presentment of motion to seal 8, motion for temporary restraining order 14, motion for miscellaneous relief, 13 before Honorable LaShonda A. Hunt on 7/8/2025 at 10:00 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. The motion hearing noticed for presentment on 7/8/25 at 10:00AM 15 is reset to a telephonic hearing at the same time. Attorneys/parties may appear by dialing: 1-650-479-3207 and entering access code: 2311 499 1046. No attendee code is required. Please review in advance the policies governing telephonic hearings that can be found on Judge Hunt's webpage on the court website. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: Telephonic motion hearing held. Plaintiff's motion for leave to file under seal 8 is granted. Schedule A 9, Exhibit 2 to the Declaration of Nicolas Lambert 11, and Plaintiff's joinder memorandum 12 shall remain sealed until further court order. Plaintiff's motion for electronic service of process 13 and ex parte motion for entry of a temporary restraining order 14 are granted. Plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. The Court finds that (1) the submitted evidence establishes a likelihood of success on the merits (including evidence of active infringement and sales into Illinois); (2) the harm to plaintiff is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with Plaintiff's ability to control its intellectual property; and (4) there is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with these online marketplace defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the Court will revisit the asset freeze, joinder, and personal jurisdiction. A $4,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable LaShonda A. Hunt on 7/8/2025. Mailed notice.

SUMMONS Issued (Court Participant) as to Defendant Aadan and all other Defendants identified in the Complaint

SUMMONS Returned Executed by Celine SA as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/10/2025, answer due 7/31/2025.

MOTION by Plaintiff Celine SA for preliminary injunction

Supplement Memorandum in Support of Motion for Preliminary Injunction

Declaration of Paul Kossof in Support of Motion for Preliminary Injunction

(Exhibit 1 to the Declaration of Paul Kossof in Support of Motion for Preliminary Injunction)

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for preliminary injunction, 24 before Honorable LaShonda A. Hunt on 7/16/2025 at 10:00 AM.

SURETY BOND in the amount of $ 4,000 posted by Celine SA. Document not imaged.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for entry of a preliminary injunction 24 is taken under advisement. Any objections to the motion are due by 7/18/25. If no objection is filed by that date, the motion will be considered unopposed. Plaintiff must serve a copy of this minute order upon all remaining defendants within one business day of its entry upon the docket and promptly file proof of that service. For the reasons stated in the Court's orders initially entering the TRO, the TRO is extended to and including the date 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, 843-845 (7th Cir. 2012). The motion hearing set for 7/16/25 25 is stricken. Mailed notice.

CERTIFICATE of Service by Plaintiff Celine SA regarding order on motion for preliminary injunction, terminate hearings, set motion and R&R deadlines/hearings, 27

MINUTE entry before the Honorable LaShonda A. Hunt: Before the Court is Plaintiff's motion for a preliminary injunction [24], which the Court now considers unopposed because no Defendant filed a notice of objection by the 7/18/25 deadline. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk that 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 on the record and in connection with entry of the TRO [20], 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 [23],[28] 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. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A [9] are added to the court's docket within five business days. The Clerk is requested to unseal any previously sealed documents. A status report regarding next steps is due by 9/1/25, if other appropriate relief has not been sought by that date. Mailed notice (gel,)

PRELIMINARY INJUNCTION ORDER Signed by the Honorable LaShonda A. Hunt on 7/28/2025. Mailed notice (gel,)

MOTION by Plaintiff Celine SA for default judgment as to All Defendants Identified on Schedule A

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for default and default judgment 31 is granted in part as to the request for entry of default. Plaintiff has shown that Defendants Aadan, Marko, Miya, and Mr. Canvas were served on 7/10/25 and failed to plead or otherwise defend this action by 7/31/25 23. Accordingly, pursuant to Federal Rule of Civil Procedure 55(a), default is entered against Defendants Aadan, Marko, Miya, and Mr. Canvas. Plaintiff's motion is entered and continued as to the request for entry of a default judgment. Any objections to the motion for entry of default judgment are due by 8/11/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve a copy of this order on all defaulted Defendants within one business day of entry and promptly file proof of such service. The motion hearing set for 8/13/25 32 is stricken. Mailed notice (gel,)

CERTIFICATE of Service by Plaintiff Celine SA regarding order on motion for default judgment, terminate deadlines, set motion and R&R deadlines/hearings, 33

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable LaShonda A. Hunt on 8/29/2025. Mailed notice (gel,)