2025-cv-08024

COMPLAINT filed by Swarovski Aktiengesellschaft, Swarovski North America Limited; Filing fee $ 405, receipt number AILNDC-23751765.

Exhibit 1

Exhibit 1

Exhibit A

Exhibit A

Declaration of Thomas J. Juettner

Declaration

(Exhibit A)

(Exhibit A)

Exhibit 1

(Exhibit 1)

(Exhibit A)

SEALED EXHIBIT by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited Schedule A regarding complaint[1]

Exhibit A

(Exhibit 2)

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Swarovski Aktiengesellschaft, Swarovski North America Limited

Notice of Claims involving Trademarks by Swarovski Aktiengesellschaft, Swarovski North America Limited

ATTORNEY Appearance for Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.)

EMAILED copy of minute order 40 to email address kwowko2022@163.com (Text entry; no document attached.)

NEW PARTIES: A1G5MTFK8VJY5P, A24OF9KAWOVAZM, A3LNWICOHIO5XX, AMZARTSHOPUS 8-14 Days Arrival, BUTIHIHAK, DSunQun, HANSEN094, HuiYiJia, JYCYSM, KMEOSCH, kristland25, Mdinsnweksk, Novelty products US, Romantic LOVE, S.T.LKY, SEAMEWRFESI, SXJZDZSMDP, UEYNTHIYV, WE HOUSE, XJAZL, xuanxuan, Yaduo777, YSTSXyy, YunFei177, alexander_ayry, Beryl Lin, Dreamy Adornments, Extraordinary YY, Jewelvoyage ye, Klein YE Jewelry, Nuyoah YE Jewelry, PonamfoBest, TRESORITE Jewelry, Elton Theresa, Leo Kingston and Zihaowei added to case caption. (Text entry; no document attached.)

EMAILED copy of minute order 41 and Plaintiff's motion to strike 36 to kwowko2022@163.com (Text entry; no document attached.)

EMAILED copy of minute order 42 to address kwowko2022@163.com (Text entry; no document attached.)

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Charles P. Kocoras: Motion for leave to file under seal [3] is granted. Mailed notice.

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Swarovski Aktiengesellschaft, Swarovski North America Limited in support of motion for temporary restraining order[14]

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

DECLARATION of Gerard Bareille regarding memorandum in support of motion[15]

SEALED EXHIBIT by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited Exhibit 2 regarding declaration[17]

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Swarovski Aktiengesellschaft, Swarovski North America Limited 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 miscellaneous relief[19], motion for temporary restraining order[14] before Honorable Charles P. Kocoras on 7/29/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for a temporary restraining order [14] and motion for electronic service of process [19] are granted. Enter temporary restraining order. Presentment hearing scheduled on 7/29/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 7/22/2025. Mailed notice.

Registry Deposit Information Form by Swarovski Aktiengesellschaft, Swarovski North America Limited

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited

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

SURETY BOND in the amount of $ 10,000 posted by Swarovski Aktiengesellschaft

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for preliminary injunction

MEMORANDUM by Swarovski Aktiengesellschaft, Swarovski North America Limited in support of motion for preliminary injunction[29]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[30]

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[29] before Honorable Charles P. Kocoras on 8/5/2025 at 09:50 AM.

SUMMONS Returned Executed by Swarovski Aktiengesellschaft, Swarovski North America Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/30/2025, answer due 8/20/2025.

PRO SE Appearance by Defendant Tletseagh (Received via pro se online portal on 7/31/2025)

RESPONSE by Defendant Tletseagh to motion for preliminary injunction [29] (Received via pro se online portal on 7/31/2025)

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited to strike Response[35]

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion to strike[36] before Honorable Charles P. Kocoras on 8/5/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Motion for Preliminary Injunction is granted. The Clerk is directed to unseal Plaintiff's Schedule A to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Gerard Bareille 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. Presentment hearing scheduled on 8/5/2025 is stricken. Status report is due on 9/3/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Charles P. Kocoras on 8/4/2025. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to strike 36 is entered and briefed as follows: Defendant Tletseagh must file a response to the motion to strike by 8/11/2025. Court will rule by mail. Presentment hearing noticed for 8/5/2025 is stricken with no appearance required. The Clerk is directed to email a copy of this Order and Plaintiff's motion to strike 36 to Defendant Tletseagh at kwowko2022@163.com. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: The Court's minute order 40 is vacated. The briefing schedule on defendant's motion to strike 36 is stricken and will be heard on 8/5/2025 at 10:15 a.m. For the telephonic motion 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. The Clerk is directed to email a copy of this Order and Plaintiff's motion to strike 36 to Defendant Tletseagh at kwowko2022@163.com. Mailed notice.

RESPONSE by Defendant Tletseagh to [36] (Received via pro se online portal on 8/4/2025)

MINUTE entry before the Honorable Charles P. Kocoras: Telephonic motion hearing held on 8/5/2025. No one appeared on behalf of Defendant Tletseagh. Plaintiff's motion to strike 36 is granted. Defendant Tletseagh's response to Plaintiff's motion for preliminary injunction 35 is stricken because there is no attorney appearance on file for Defendant Tletseagh. Corporations and other business entities must be represented by an attorney. See Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851, 857-58 (7th Cir. 2011); see also In re IFC Credit Corp., 663 F.3d 315, 318 (7th Cir. 2011) ("Corporations unlike human beings are not permitted to litigate pro se. Inability to litigate pro se can be thought of as part of the price for corporations' privileges."); Scandia Down Corp. v. Euroquilt, Inc., 772 F.2d 1423, 1427 (7th Cir. 1985) ("[C]orporations must appear by counsel or not at all."). A status report regarding the remaining defendants, the status of settlement negotiations (including with Defendat Tletseagh specifically), and Plaintiff's proposed next steps in the case remains due on 9/3/2025. The Clerk's Office is directed to send a copy of this order to Defendant Tletseagh at kwowko2022@163.com. Mailed notice.

NOTICE of Voluntary Dismissal by Swarovski Aktiengesellschaft, Swarovski North America Limited as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 44 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

NOTICE of Voluntary Dismissal by Swarovski Aktiengesellschaft, Swarovski North America Limited as to Certain Defendants

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited to approve consent judgment as to Defendant Tletseagh (Def. No. 36) (Agreed)

MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for entry of default, MOTION by Plaintiffs Swarovski Aktiengesellschaft, Swarovski North America Limited for default judgment as to all Defendants

MEMORANDUM by Swarovski Aktiengesellschaft, Swarovski North America Limited in support of motion for entry of default, motion for default judgment, 48

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 49

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, 48, motion to approve consent judgment 47 before Honorable Charles P. Kocoras on 9/2/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 46 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to approve consent judgment as to defendant Tletseagh (Def. No. 36) 47 and entry of default and default judgment 48 are granted. Enter consent judgment and default judgment order. Presentment hearing scheduled on 9/2/2025 is stricken. Civil case terminated. Mailed notice.

CONSENT JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 8/29/2025. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 8/29/2025. Mailed notice.

MAILED trademark report with order dated 8/29/2025 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 55 in the amount of $500,000 as to certain defendants