IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

CHRISTIAN DIOR COUTURE, S.A., 

Plaintiff, 

v. 

CHINABRANDMALL.COM, et al., 

Defendants. 

Case No. 20-cv-02421 

Judge Robert W. Gettleman 

Magistrate Judge Susan E. Cox

NOTICE OF CLAIMS INVOLVING TRADEMARKS

Pursuant to Local Rule 3.4, Plaintiff Christian Dior Couture, S.A. (“Dior”), by and 

through its counsel, hereby provides notice of claims involving trademarks. The information 

required by the rule and 15 U.S.C. §1116(c) is as follows: 

1. Names and Addresses of Litigants: 

Christian Dior Couture, S.A. 

30 avenue Montaigne F-75008 

Paris, France 

CHINABRANDMALL.COM, et al. 

Addresses Unknown 

2. U.S. Registration Numbers Upon Which Suit Has Been Brought: 

REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

543,994 CHRISTIAN DIOR June 19, 1951 For: Handbags and pocketbooks 

in Class 018. 

580,207 CHRISTIAN DIOR September 22, 

1953 

For: Jewelry for personal wear, 

not including watches-namely, 

trinkets, necklaces, bracelets, 

finger rings, earrings, brooches, 

and ornamental clips made in 

whole of, in part of, or plated with 

precious metals in class 014. 

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

954,404 CHRISTIAN DIOR March 6, 1973 For: Eyeglass frames, sunglasses 

and eyeglass cases in Class 009. 

1,123,944 CD August 14, 

1979 

For: Optical apparatus – namely, 

eyeglass frames in Class 009. 

For: Jewelry and horological 

instruments – namely, women’s 

costume jewelry, bracelets, and 

watches for men and women in 

Class 014. 

For: Articles made from leather 

and imitations thereof, namely, 

luggage for men and women in 

Class 018. 

For: Women’s blouses, skirts, 

dresses, jackets, suits, coats; 

Men’s suits, belts and sport 

jackets in Class 025. 

1,776,536 June 15, 1993 For: Carry-on bags; change 

purses; clutch bags; clutch purses; 

golf umbrellas; handbags; 

luggage; passport cases, holders or 

wallets; pocketbooks; purses; 

shoulder bags; all-purpose sports 

bags; suitcases; tote bags; travel 

bags; and wallets in Class 018. 

For: Clothing for use by men, 

women and children; namely, 

blouses; gloves; vests in Class 

025. 

1,872,313 January 10, 

1995 

For: Eyeglass frames and parts 

thereof; sunglasses in Class 009. 

For: Rings in Class 014. 

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

1,923,564 October 3, 

1995 

For: Belt buckles of precious 

metals for clothing; brooches; 

charms; costume jewelry; ear 

clips; jewelry; jewelry lapel pins; 

ornamental pins; pendants; watch 

bands; watch chains; watch fobs; 

and watches in Class 014. 

For: billfolds; business card cases; 

carry-on bags; change purses; 

clutch bags; clutch purses; coin 

purses; credit card cases; 

drawstring pouches; handbags; 

key cases; overnight bags; 

passport cases, holders or wallets; 

purses; shoulder bags; and wallets 

in Class 018. 

2,240,163 April 20, 1999 For: clutch bags, change purses, 

pocketbooks, purses, wallets in 

class 018. 

3,561,323 January 13, 

2009 

For: optical apparatus and 

instruments, namely, spectacles, 

sunglasses, spectacle cases, and 

spectacle frames in Class 009. 

2,749,176 August 12, 

2003 

For: Athletic bags; attache cases; 

baby carriers worn on the body; 

backpacks; beach bags; beach 

umbrellas; billfolds; book bags; 

briefcase-type portfolios; 

briefcases; business card cases; 

carry-on bags; non-motorized 

collapsible luggage carts; change 

purses; clutch bags; clutch purses; 

coin purses; cosmetic cases sold 

empty; credit card cases; diaper 

bags; document cases; drawstring 

pouches; duffel bags; fanny packs; 

felt pouches; garment bags for 

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

travel; golf umbrellas; gym bags; 

handbags; hat boxes for travel; 

key cases; knapsacks; luggage; 

overnight bags; overnight cases; 

parasols; passport cases, holders 

and wallets; patio umbrellas; 

pocketbooks; purses; satchels; 

school bags; shoe bags for travel; 

leather shopping bags; mesh 

shopping bags; textile shopping 

bags; shoulder bags; all-purpose 

sports bags; suitcases; toiletry 

cases sold empty; tote bags; travel 

bags; trunks for traveling; 

umbrellas; valises; vanity cases 

sold empty; waist packs; wallets 

in Class 018. 

For: Clothing for use by men, 

women and children; namely, 

anoraks; aprons; ascots; 

babushkas; bandannas; bathing 

suits; bathrobes; belts; blazers; 

blouses; blousons; bodysuits; 

boleros; boots; boxer shorts; 

brassieres; briefs; baby buntings; 

caftans; camisoles; capes; caps; 

cardigans; chemises; clogs; cloth 

diapers; fur coats; suit coats; top 

coats; corselets; culottes; dresses; 

earmuffs; galoshes; garter belts; 

girdles; gloves; nightgowns; halter 

tops; hats; headbands; hosiery; 

jackets; jeans; jogging suits; 

jumpers; jumpsuits; kerchiefs; 

kimonos; leggings; leotards; 

loungewear; mittens; moccasins; 

mufflers; neckerchiefs; neckties; 

neckwear; negligees; nightshirts; 

overalls; overcoats; overshoes; 

pajamas; panties; pants; pantsuits; 

pantyhose; parkas; pedal pushers; 

peignoirs; pinafores; playsuits; 

pocket squares; ponchos; 

Case: 1:20-cv-02421 Document #: 25 Filed: 04/23/20 Page 4 of 8 PageID #:2984
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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

pullovers; raincoats; sandals; 

scarves; shawls; shirts; shorts; 

undershirts; shoes; sweat shorts; 

skirts; ski suits; slacks; snowsuits; 

socks; sport coats; sport shirts; 

stockings; stoles; suits; 

suspenders; sweat pants; 

sweatshirts; sweaters; t-shirts; 

trousers; tuxedos; underpants; 

vests; vested suits; and warm-up 

suits in Class 025. 

5,173,476 DIOR SO REAL April 4, 2017 For: Eyeglasses, sunglasses, 

goggles for sports; spectacle 

frames, spectacle cases; containers 

for contact lenses; protective 

cases, bags, satchels and covers 

for computers, tablets, mobile 

telephones and MP3 players in 

Class 009. 

For: Jewelry; precious stones; 

precious metals and their alloys, 

jewelry bracelets, jewelry 

brooches, jewelry necklaces, 

jewelry chains, medals, pendants, 

earrings, rings, charms, tie pins; 

cuff links; key rings of precious 

metals; jewelry cases; boxes of 

precious metal; boxes, cases and 

presentation cases for timepieces 

and jewelry; timepieces, 

chronometric instruments, 

watches, watch bands in Class 

014. 

For: Leather and imitation leather; 

animal skins and furs; trunks and 

suitcases; wallets; coin purses; 

credit card holders; briefcases of 

leather or imitation leather; key 

cases of leather or imitation 

leather; garment bags for travel; 

all-purpose carrying bags, 

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

backpacks, handbags, traveling 

bags; vanity cases sold empty; 

clutch bags of leather; toiletry and 

make-up bags sold empty; boxes 

of leather; umbrellas in Class 018. 

5,505,434 J'ADIOR July 3, 2018 For: Eyeglasses, sunglasses, 

goggles for sports; spectacle 

frames, spectacle cases; protective 

cases, bags, satchels and covers 

for computers, tablets, mobile 

telephones and MP3 players; 

cases for telephones, protective 

cases for telephones in Class 009. 

For: Jewelry, jewelry articles; 

precious and semi-precious 

stones; pearls; precious metals and 

their alloys; items of jewelry, 

namely, bracelets, brooches, 

necklaces, chains, medals, 

pendants, earrings, rings, and 

charms; tie pins; cuff links; key 

rings; jewelry cases; boxes of 

precious metals; presentation 

boxes and cases for jewelry and 

timepieces; timepieces; 

chronometric instruments; 

watches; watch bands; watch 

dials; chronographs in Class 014. 

For: Leather and imitation leather; 

animal skins and fur pelts; trunks 

and suitcases; wallets; coin 

purses; credit card holders; 

briefcases of leather or imitation 

leather; attaché cases and 

document cases of leather and 

imitation leather; protective 

covers for clothing, namely, 

garment bags for travel; key cases 

of leather or imitation leather; allpurpose carrier bags; backpacks; 

handbags; traveling bags; vanity

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

cases sold empty; clutch bags of 

leather; traveling sets being 

luggage of leather; toiletry and 

make-up bags sold empty; leather 

boxes not being jewelry boxes; 

umbrellas; shoulder belts of 

leather in Class 018. 

For: Clothing, namely, layettes, 

bibs not of paper, bath robes, 

bathing suits, shorts, belts, 

suspenders, blouses, cardigans, 

trousers, overalls, combinations, 

shirts, t-shirts, skirts, polo shirts, 

pullovers, vests, dresses, coats, 

tailleurs, parkas, overcoats, 

blousons, jackets, underwear, furs 

being clothing, wedding dresses, 

gloves, mittens, scarves, stoles, 

sashes for wear, shawls, neckties, 

collars, caps, hats, visors, hosiery, 

men's suits, ponchos, raincoats, 

socks, tights, leggings, pajamas, 

tracksuits, cuffs, and bedroom 

slippers; footwear; beach, ski, and 

sports footwear; boots; ankle 

boots; sandals; pumps being 

footwear; esparto shoes and 

sandals; headbands; headwear; 

headgear being knitted caps; 

clothing for sports, namely, shorts 

and shirts; clothing for children, 

namely, hats, shorts, dresses, and 

shoes in Class 025. 

3,002,132 September 27, 

2005 

For: Jewelry; jewelry chains; 

charms, medals; pins being 

jewelry in Class 014. 

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REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

2,790,589 December 9, 

2003 

For: Optical apparatus and 

instruments, namely, spectacles, 

sunglasses in Class 009. 

For: Precious metals in general 

and their alloys sold in bulk; 

precious metals and their alloys 

sold at retail; jewelry, charms, 

medals in Class 014. 

For: Clothing for use by men, 

namely, blousons; boxer shorts; 

cardigans; neckties; neckwear; 

pants; pullovers; scarves; shirts; 

shorts; sweat shorts; sport shirts; 

sweatshirts; sweaters; t-shirts; 

trousers in Class 025. 

Dated this 23rd day of April 2020. Respectfully submitted, 

/s/ Justin R. Gaudio_____________ 

Amy C. Ziegler 

Justin R. Gaudio 

Allyson M. Martin 

Greer, Burns & Crain, Ltd. 

300 South Wacker Drive, Suite 2500 

Chicago, Illinois 60606 

312.360.0080 

312.360.9315 (facsimile) 

 aziegler@gbc.law 

 jgaudio@gbc.law 

amartin@gbc.law 

Counsel for Plaintiff Christian Dior Couture, S.A. 

Case: 1:20-cv-02421 Document #: 25 Filed: 04/23/20 Page 8 of 8 PageID #:2988