2025-cv-07343

COMPLAINT filed by Celine SA; Filing fee $ 405, receipt number AILNDC-23690266.

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

DECLARATION of Nicolas Lambert

(Exhibit 1 to the Declaration of Nicolas Lambert)

SEALED DOCUMENT by Plaintiff Celine SA Schedule A

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

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

MOTION by Plaintiff Celine SAfor electronic service of process.

Supplement Memorandum in Support of Motion for Electronic Service

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 Georgia N Alexakis. Designated as Magistrate Judge the Honorable Maria Valdez. 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 for miscellaneous relief, 13, motion to seal 8, motion for temporary restraining order 14 before Honorable Georgia N Alexakis on 7/15/2025 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 9/8/25 at 9:30 a.m. in person in Courtroom 1719. By 9/2/25, the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion to seal 8, motion for electronic service of process 13, and ex parte motion for entry of a temporary restraining order 14. No appearance is required on 7/15/25. Based on plaintiff's written submissions, the Court finds that plaintiff has established (1) a likelihood of success on the merits; (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. Plaintiff's written submissions also establish that if defendants were informed of this proceeding before a TRO could issue, assets representing proceeds from the sale of the infringing products would likely be redirected, defeating plaintiff's interests in stopping the infringement and obtaining an accounting. Expedited discovery is warranted to identify defendant and implement the asset freeze. 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. The Court decides these motions, though, without the benefit of adversarial presentation. If defendant were to appear and object, the Court is willing revisit issues related to, among other topics, the asset restraint, personal jurisdiction, joinder, and electronic service of process. A $10,000 bond is sufficient to secure the injunctive relief. Enter order, as modified by the Court.

SEALED Temporary Restraining Order. Signed by the Honorable Georgia N Alexakis on 7/14/25.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SUMMONS Returned Executed by Celine SA as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/16/2025, answer due 8/6/2025.

MOTION by Plaintiff Celine SA for preliminary injunction

Supplement Memorandum in Support of Motion for Preliminary Injunction

Declaration of Paul Kossof in Support of Memorandum 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 Georgia N Alexakis on 7/21/2025 at 09:30 AM.

SURETY BOND in the amount of $ 10,000.00 posted by Celine SA. (Document not scanned)

MINUTE entry before the Honorable Georgia N Alexakis: Before the Court is plaintiff's motion for entry of a preliminary injunction 24, which the Court takes under advisement. All defendants are advised that the Court will consider the motion unopposed if no defendant files a notice of objection by 7/25/25. Consistent with Federal Rule of Civil Procedure 65(a), plaintiff must serve a copy of its motion for entry of a preliminary injunction and this minute order upon all defendants within one business day and promptly file proof of that service. The Court resets the hearing on plaintiff's motion for a preliminary injunction from 7/21/25 to 7/31/25 at 9:30 a.m.

CERTIFICATE of Service by Plaintiff Celine SA regarding MOTION by Plaintiff Celine SA for preliminary injunction 24, terminate hearings, set/reset hearings, 27

MOTION by Plaintiff Celine SA for extension of time of temporary restraining order

(Declaration of Paul Kossof in Support of Motion to Extend Temporary Restraining Order)

NOTICE of Motion by Paul Joseph Kossof for presentment of extension of time 29 before Honorable Georgia N Alexakis on 7/24/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Ex parte motion to extend the Temporary Restraining Order 29 is granted. The Temporary Restraining Order entered on 7/14/25 23 is extended by a period of 14 days until 8/11/25. No appearance is required on 7/24/25.

MINUTE entry before the Honorable Georgia N Alexakis: 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 7/25/25 deadline. For the reasons set forth in plaintiff's motion for a preliminary injunction, as well as the reasons provided by plaintiff in connection with the Court's earlier entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction, including that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the sale of counterfeit goods. Enter Preliminary Injunction Order, as modified by the Court. Plaintiff's counsel is directed to ensure that all defendants listed on the Schedule A [10] are added to the court's docket by 8/5/25. The Clerk is requested to unseal any previously sealed documents. Summons were returned executed on 7/16/25 and defendants' answers or responses to the complaint are due by 8/6/25 [33]. By 8/20/25, plaintiff is ordered to file any motion for entry of default and default judgment pursuant to Federal Rule of Civil Procedure 55. If there are any remaining defendants against whom default and default judgment are not being sought, plaintiff is ordered to file by the same date a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. No appearance is required on 7/31/25. The Court further vacates the 9/2/25 deadline for filing a joint initial status report and the 9/8/25 initial status hearing.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Georgia N Alexakis on 7/29/25.

NOTICE of Voluntary Dismissal by Celine SA of Defendants Yiling luxe and Ai Weiyuan

MOTION by Plaintiff Celine SA for default judgment as to Defendants 1-4, 6-11, and 13

Supplement Memorandum in Support of Motion for Default Judgment

Declaration of Paul Kossof in Support of Motion for Default Judgment

(Exhibit 1 to the Declaration of Paul Kossof in Support of Motion for Default Judgment)

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for default judgment, 35 before Honorable Georgia N. Alexakis on 8/14/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N. Alexakis: Plaintiff seeks entry of default as to Defendants 1 through 4, 6 through 11, and 13, the remaining defendants in this matter. Defendants 1 through 4, 6 through 11, and 13 have failed either to plead or to otherwise appear to defend against this action. Accordingly, default against Defendants 1 through 4, 6 through 11, and 13 is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by the Defaulting Defendants must be filed on or before 8/28/25. Plaintiff must serve this minute order upon the Defaulting Defendants within one business day of its entry on the docket and must promptly file proof of that service. The Court re-sets the hearing on plaintiff's motion seeking default judgment as to the Defaulting Defendants from 8/14/25 to 9/4/25 at 9:30 a.m. By 8/28/25, plaintiff is directed to supplement its motion for default judgment with information that would allow the Court to make more precise and individualized damages determinations per Defaulting Defendant. For example, plaintiff could explain what its investigation, aided by expedited discovery 19, unearthed with respect to estimated revenue generated by each Defaulting Defendant through the sale of infringing products, or estimated number of infringing products each Defaulting Defendant sold, or the estimated length of time that each Defaulting Defendant has been engaged in the sale of infringing products. If plaintiff does not have such information (or other information in the same vein), it should explain why it has been unable to obtain it with a reasonable degree of specificity.

CERTIFICATE of Service by Plaintiff Celine SA regarding terminate hearings, set/reset hearings, 37

MINUTE entry before the Honorable Georgia N. Alexakis: Per plaintiff's notice of voluntary dismissal 34, pursuant to Federal Rule of Civil Procedure 41(a)(1), Defendants Yiling luxe and Ai Weiyuan are dismissed with prejudice.

Memorandum Regarding Plaintiffs Investigation into Defendants Revenue from the Sale of Counterfeit Goods by Celine SA