2025-cv-08244

COMPLAINT filed by Hollywood Chamber of Commerce; Filing fee $ 405, receipt number AILNDC-23771229.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Marcella D. Slay

Declaration of Rachel M. Ackerman

Exhibit A

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Schedule A regarding complaint[1]

Exhibit A

Exhibit 2

MOTION by Plaintiff Hollywood Chamber of Commerce for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hollywood Chamber of Commerce

Notice of Claims Involving Trademarks by Hollywood Chamber of Commerce

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Rachel Meira Ackerman

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

BOND in the amount of $5,000 check, Receipt No. 100022453, posted by Hollywood Chamber of Commerce. (Text entry; no document attached.)

NEW PARTIES: Asamour, DecorLion, Doitely, Hangzhou Xinde Handicraft Co., Ltd., Hmxpls, MASTORE and Nenluny added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MOTION by Plaintiff Hollywood Chamber of Commerce for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for temporary restraining order[13]

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

DECLARATION of Steve Nissen regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff Hollywood Chamber of Commerce Exhibit 2 regarding declaration[16]

MOTION by Plaintiff Hollywood Chamber of Commerce for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 7/24/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Hollywood Chamber of Commerce

Registry Deposit Information Form by Hollywood Chamber of Commerce

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

MOTION by Plaintiff Hollywood Chamber of Commerce for preliminary injunction

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for preliminary injunction[27]

SUMMONS Returned Executed by Hollywood Chamber of Commerce as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/4/2025, answer due 8/25/2025.

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [27] is set for 8/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

ATTORNEY Appearance for Plaintiff Hollywood Chamber of Commerce by Trevor Christian Talhami

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 8/7/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [27] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibits to the Declaration of Steven Nissen [17], and the TRO [23]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 9/12/2025 at 9:30 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 8/7/2025. Mailed notice.

ATTORNEY Appearance for Defendant Hmxpls by Steven G Kalberg

NOTICE of Voluntary Dismissal by Hollywood Chamber of Commerce as to certain defendant

NOTICE of Voluntary Dismissal by Hollywood Chamber of Commerce as to certain defendants

MOTION by Defendant Hmxpls for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer [37] is granted. Defendant No. 5 Hmxpls is to answer Plaintiffs' Complaint by 9/24/2025. Mailed notice.

MOTION by Plaintiff Hollywood Chamber of Commerce for entry of default, MOTION by Plaintiff Hollywood Chamber of Commerce for default judgment as to all remaining Defendants with the exception of a certain Defendant

MEMORANDUM by Hollywood Chamber of Commerce in support of motion for entry of default, motion for default judgment, [39]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[40]

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/12/2025 at 9:30 a.m. is converted to a telephone hearing as to the motion for entry of default and default judgment [39]. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone hearing as to the motion for entry of default and default judgment [39] set for 9/12/2025 is reset for 9/11/2025 at 9:30 a.m. Mailed notice.