2025-cv-08366

COMPLAINT filed by Kendra Scott, LLC; Filing fee $ 405, receipt number AILNDC-23780493.

Exhibit 1

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Luana Faria de Souza

Declaration of Rachel M. Ackerman

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Schedule A regarding complaint[1]

Exhibit A

(Exhibit B)

Exhibit 2

Exhibit B

MOTION by Plaintiff Kendra Scott, LLC for leave to file under seal

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Kendra Scott, LLC

Notice of Claims Involving Trademarks by Kendra Scott, LLC

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Luana Faria De Souza (Faria De Souza, Luana)

ATTORNEY Appearance for Plaintiff Kendra Scott, LLC by Rachel Meira Ackerman

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Albert Berry, III. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

BOND in the amount of $ 3,000 check, Receipt No. 100022907 posted by Kendra Scott, LLC. (Text entry; no document attached.)

NEW PARTIES: Gansu Dongshengyuan Trading Co., Ltd., Guangzhou LoveYan E-commerce Co., Ltd., Yiwu Zhuofang jewelry Co., Ltd., COSH Jewelry, Duecare Store, Jilin Qisheng department store, Nashuo Store, nuolewei-US, nuooukaina-US, sanjing1, shijingjiee, SYLDMJ, THANHTHAI, WARMDAY Jewelry, XL-TT-SHOPS, AK Jewelry, beijingshimiyunqumingzh, Can shop, Chuanfuwang, Daily, dayuanguan, dingconglin, Elegance Jewelers, guandongxu, hexingzhen, luoshiyachuanmei, LuxeWorld, mixiaguo, qianbangcongshangmao, SK.Jewelers, Super Buyer's Store, Teng Fei Department Store, The Land of Gems, Wsupikio, xiongandenanwangluokeji and Z.ZK LLC added to case caption. (Text entry; no document attached.)

Terminating Can shop, Chuanfuwang, Daily, Duecare Store, Elegance Jewelers, Gansu Dongshengyuan Trading Co., Ltd., Guangzhou LoveYan E-commerce Co., Ltd., Jilin Qisheng department store, LuxeWorld, Nashuo Store, SYLDMJ, Super Buyer's Store, THANHTHAI, Teng Fei Department Store, The Land of Gems, WARMDAY Jewelry, Wsupikio, XL-TT-SHOPS, Yiwu Zhuofang jewelry Co., Ltd., beijingshimiyunqumingzh, dayuanguan, dingconglin, guandongxu, hexingzhen, luoshiyachuanmei, mixiaguo, nuolewei-US, nuooukaina-US, qianbangcongshangmao, sanjing1, shijingjiee, AK Jewelry and COSH Jewelry (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA. (jn,)

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

AMENDED complaint by Kendra Scott, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Amended Schedule A regarding amended complaint[13]

MOTION by Plaintiff Kendra Scott, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Kendra Scott, LLC in support of motion for temporary restraining order[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

DECLARATION of Adrienne T. Montes regarding memorandum in support of motion[16]

SEALED EXHIBIT by Plaintiff Kendra Scott, LLC Exhibit 2 - Part 1 regarding declaration[18]

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

MEMORANDUM by Kendra Scott, LLC in support of motion for miscellaneous relief[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

MINUTE entry before the Honorable John J. Tharp, Jr: By 7/31/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

RESPONSE by Plaintiff Kendra Scott, LLC to text entry, [23]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [15] is granted. Plaintiff's motions for leave to file under seal [3] and for electronic service of process [20] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 7/30/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Kendra Scott, LLC (Faria De Souza, Luana)

Registry Deposit Information Form by Kendra Scott, LLC (Faria De Souza, Luana)

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

MOTION by Plaintiff Kendra Scott, LLC for preliminary injunction

MEMORANDUM by Kendra Scott, LLC in support of motion for preliminary injunction[30]

SUMMONS Returned Executed by Kendra Scott, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/8/2025, answer due 8/29/2025.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 30 is taken under advisement. Any objection or response is due before 8/14/2025. Upon review of the certificate of service, the Court directs the plaintiff, by 8/12/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 8/14/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Kendra Scott, LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 33

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [30] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 8/19/2025 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 8/15/2025. Mailed notice

MOTION by Plaintiff Kendra Scott, LLC for entry of default, MOTION by Plaintiff Kendra Scott, LLC for default judgment as to all Defendants

MEMORANDUM by Kendra Scott, LLC in support of motion for entry of default, motion for default judgment[37]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[38]

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's motion for entry of default and default judgment [37] is taken under advisement. Any objections or responses are due by 9/15/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 9/8/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Kendra Scott, LLC regarding order on motion for entry of default, order on motion for default judgment, terminate motions, [40]