2025-cv-11637

COMPLAINT filed by Chrome Hearts LLC; Filing fee $ 405, receipt number AILNDC-24112699.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-2 regarding complaint[1]

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Chrome Hearts LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chrome Hearts LLC

Notice of Claims Involving Trademarks by Chrome Hearts LLC

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2). (qrtr,) (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED copyright report to Registrar, Washington DC

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

MEMORANDUM by Chrome Hearts LLC in support of motion for temporary restraining order[15]

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

DECLARATION of Mario Lejtman regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Chrome Hearts LLC Exhibit 3 - Parts 1-2 regarding declaration[18]

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

MEMORANDUM by Chrome Hearts LLC in support of motion for miscellaneous relief[20]

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[4], motion for temporary restraining order[15], motion for miscellaneous relief[20] before Honorable Jorge L. Alonso on 10/2/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [4] [15] [20] are granted, and no appearance is necessary. The 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. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. 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, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $62,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 10/2/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 10/2/2025.

Registry Deposit Information Form by Chrome Hearts LLC

SUMMONS Submitted (Court Participant) for defendant(s) A15MECI91IP0E and all other Defendants identified in the Complaint by Plaintiff Chrome Hearts LLC

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

SURETY BOND in the amount of $62,000 posted by Chrome Hearts LLC (Document not scanned)

MOTION by Plaintiff Chrome Hearts LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Chrome Hearts LLC in support of extension of time[29]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[30]

NOTICE of Motion by Trevor Christian Talhami for presentment of extension of time[29] before Honorable Jorge L. Alonso on 10/16/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend temporary restraining order [29] is granted. The temporary restraining order is extended for 14 days to 10/30/25. Motion hearing date of 10/16/25 is stricken. Notice mailed by Judge's staff

MOTION by Plaintiff Chrome Hearts LLC for preliminary injunction

Exhibit A

MEMORANDUM by Chrome Hearts LLC in support of motion for preliminary injunction[34]

Declaration of Trevor C. Talhami

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[34] before Honorable Jorge L. Alonso on 10/21/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Chrome Hearts LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/16/2025, answer due 11/6/2025.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/21/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Chrome Hearts LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [34] is granted. Enter Preliminary injunction order. The Clerk's office is directed to unseal all previously sealed documents. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

NEW PARTIES: A15MECI91IP0E, A1V8TT7B5OMT83, A2PCYTG0OBAX1I, A305FLOLOKL979, A3712X6G8BB5WI, A3UZF21DJSW02B, AQZDWTOVND7FK, ataishangmao, CHENSHAOLIANGSTORE, CUSTOM LLC, Dormklss, FangOuFF, gaokaifafaping, H2OKMAH, haerbinyuepaidianligongchengyouxiangongsi, LinLinYang, lizhenguo store, Luo JianZheng, meile, Mi ys, mingkun shop, mixumixu, MRWANGTAOSHANGMAOBAIHUO, MTL Sports, OMCA Store, Revitalizing China, ShanXiQinZhiYuanWenHuaFaZhanYouXianGongSi, Shuflame Nail Art Store, Star Point Accessories, TaiYuanShiYiJiaKaiSuoYouXianGongSi, THNG NOWA, VERAMI Jewelry, xcjcai2, Xinsumaoyi, YINXINGYE, yongguanshangmao, ZhangXinYanshangmao, ZHENG CHANGYUAN, zixibaihuo, ZRXYJD, caicai.107170, da.nni9660, hushuyang2, vinom97720, zwluxury1, HB JEWELRY local, lemeijinpindian, ccbfc.xyz, chromeheartscom.us, chromeheartshoodieco.us, chromeheartsreal.com, chromeheartus.com, chromesupply.com, david-studio.com, deptsshop.com, jenacase.com, labami.com, thechromeheartsclothings.com, thesouthvibe.com, 407131796, FC factory from China and luxury999designer added to case caption. (Text entry; no document attached.)

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/21/2025. Notice mailed by Judge's staff