1 

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

Declaration of Nicolas Lambert

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 1 of 18 PageID #:558
2 

DECLARATION OF NICOLAS LAMBERT 

I, Nicolas Lambert, declare and state as follows: 

1. This declaration is based upon my personal knowledge of the facts stated herein or on the 

business records that were made at the time or in the regular course of business. If called 

as a witness, I could and would testify to the statements made herein. 

2. I have been employed by LVMH Moët Hennessy Louis Vuitton SA (“LVMH”) in Paris, 

France since 2016 and I am duly empowered to represent Christian Dior Couture, S.A. 

(“Dior”). In my capacity as LVMH’s Head of Online Markets Protection, I am 

responsible, in part, for Dior’s trademark and anti-counterfeiting efforts in connection 

with Internet related matters. I am knowledgeable about or have access to business 

records concerning all information referenced herein, including, but not limited to, Dior’s 

trademarks, copyrights, other intellectual property, sales, on-line sales, advertising, 

marketing, media coverage and anti-counterfeiting activities. I make this declaration 

from matters within my own knowledge save where otherwise stated. 

3. Dior is a world-famous couturier engaged in the business of styling and selling diverse 

articles of men’s and women’s apparel and fashion accessories. Dior is famous for its 

leadership, style, excellence, and quality in the field of fashion, and is widely recognized 

as one of the principal style innovators and leaders in the fashion field. Dior is engaged in 

the manufacture, sale and distribution of prestigious, high-quality, luxury merchandise, 

including a wide variety of clothing and fashion accessories, eyewear, leather goods, 

jewelry, watches, and other similar items sold throughout the United States (collectively, 

the “Dior Products”), all of which prominently display its famous, internationallyrecognized and federally-registered trademarks, including CHRISTIAN DIOR, DIOR, 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 2 of 18 PageID #:559
3 

CD, and (the “Cannage Design”). Dior Products have become enormously 

popular and even iconic, driven by Dior’s arduous quality standards and innovative 

designs. Among the purchasing public, genuine Dior Products are instantly recognizable 

as such. In the United States and around the world, the Dior brand has come to symbolize 

high quality, and Dior Products are among the most recognizable of their kind in the 

world. 

4. Dior Products are distributed and sold to consumers through retailers throughout the 

United States in company-operated Dior boutiques and in high-quality department stores 

in Illinois such as Barneys, Bloomingdales, Nordstrom, Neiman Marcus, and Saks Fifth 

Avenue. 

5. Dior incorporates a variety of distinctive marks in the design of its various Dior Products. 

As a result of its long-standing use, Dior owns common law trademark rights in its 

trademarks. Dior has also registered its trademarks with the United States Patent and 

Trademark Office. Dior Products typically include at least one of Dior’s registered 

trademarks and/or copyrighted designs (the “Dior Copyrighted Designs”). Often several 

Dior marks are displayed on a single product. Dior uses its trademarks in connection with 

the marketing of its Dior Products, including the following marks which are collectively 

referred to as the “CHRISTIAN DIOR Trademarks.” 

REGISTRATION

NUMBER

REGISTERED

TRADEMARK

REGISTRATION

DATE

INTERNATIONAL

CLASSES

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

in Class 018. 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 3 of 18 PageID #:560
4 

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. 

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. 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 4 of 18 PageID #:561
5 

1,872,313 January 10, 

1995 

For: Eyeglass frames and parts 

thereof; sunglasses in Class 009. 

For: Rings in Class 014. 

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 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 5 of 18 PageID #:562
6 

empty; credit card cases; diaper 

bags; document cases; drawstring 

pouches; duffel bags; fanny packs; 

felt pouches; garment bags for 

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; 

pullovers; raincoats; sandals; 

scarves; shawls; shirts; shorts; 

undershirts; shoes; sweat shorts; 

skirts; ski suits; slacks; snowsuits; 

socks; sport coats; sport shirts; 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 6 of 18 PageID #:563
7 

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, 

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.

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 7 of 18 PageID #:564
8 

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 

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, 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 8 of 18 PageID #:565
9 

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. 

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. 

6. The CHRISTIAN DIOR Trademarks have been used exclusively and continuously in the 

U.S. by Dior, and have never been abandoned. The above registrations for the 

CHRISTIAN DIOR Trademarks are valid, subsisting, in full force and effect, and many 

are incontestable pursuant to 15 U.S.C. § 1065. True and correct copies of the above 

United States Registration Certificates are attached hereto as Exhibit 1. 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 9 of 18 PageID #:566
10 

7. The CHRISTIAN DIOR Trademarks are exclusive to Dior, and are displayed extensively 

on Dior Products and in Dior’s marketing and promotional materials. Dior Products have 

long been among the most famous and popular of their kind in the world and have been 

extensively promoted and advertised at great expense. In fact, Dior has expended 

millions of dollars annually in advertising, promoting and marketing featuring the 

CHRISTIAN DIOR Trademarks. Dior Products have also been the subject of extensive 

unsolicited publicity resulting from their high quality and popularity among high profile 

celebrities who don Dior Products at red carpet events. Representative photographs of 

celebrities adorned with Dior Products at red carpet events are attached hereto as Exhibit 

2. Because of these and other factors, the Dior name and the CHRISTIAN DIOR 

Trademarks have become famous throughout the United States. 

8. The CHRISTIAN DIOR Trademarks are distinctive when applied to the Dior Products, 

signifying to the purchaser that the products come from Dior and are manufactured to 

Dior’s quality standards. Whether Dior manufactures the products itself or licenses others 

to do so, Dior has ensured that products bearing its trademarks are manufactured to the 

highest quality standards. The CHRISTIAN DIOR Trademarks have achieved 

tremendous fame and recognition, which has only added to the distinctiveness of the 

marks. As such, the goodwill associated with the CHRISTIAN DIOR Trademarks is of 

incalculable and inestimable value to Dior. 

9. Since at least as early as 1999, Dior has operated a website where it promotes Dior 

Products at dior.com. Dior Products are featured and described on the website, and, since 

2001, some of them are available for purchase. The dior.com website features proprietary 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 10 of 18 PageID #:567
11 

content, images, and designs exclusive to Dior. Attached hereto as Exhibit 3 is a true and 

correct copy of a portion of the dior.com website. 

10. The Dior Copyrighted Designs are registered with the United States Copyright Office. 

The registrations include, but are not limited to: “BEE” (U.S. Copyright Registration No. 

VA 657-906), issued by the Register of Copyrights on June 17, 1994; “BEE” (U.S. 

Copyright Registration No. VA 655-762), issued by the Register of Copyrights on June 

17, 1994; “BEE” (U.S. Copyright Registration No. VA 657-903), issued by the Register 

of Copyrights on June 17, 1994; “BEE” (U.S. Copyright Registration No. VA 657-904), 

issued by the Register of Copyrights on June 17, 1994; and “BEE” (U.S. Copyright 

Registration No. VA 657-905), issued by the Register of Copyrights on June 17, 1994. 

True and correct copies of the U.S. federal copyright registration certificates for the 

above-referenced Dior Copyrighted Designs are attached hereto as Exhibit 4. 

11. Dior has expended substantial time, money, and other resources in developing, 

advertising and otherwise promoting the CHRISTIAN DIOR Trademarks. As a result, 

products bearing the CHRISTIAN DIOR Trademarks are widely recognized and 

exclusively associated by consumers, the public, and the trade as being high quality 

products from Dior. Dior is a multi-million-dollar operation, and Dior Products have 

become among the most popular of their kind in the world. 

12. The success of the Dior brand has resulted in its significant counterfeiting. Consequently, 

Dior has a worldwide anti-counterfeiting program and regularly investigates suspicious ecommerce stores identified in proactive Internet sweeps and reported by consumers. In 

recent years, Dior has identified numerous fully interactive e-commerce stores, including 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 11 of 18 PageID #:568
12 

those1 operating under the seller aliases identified in Schedule A to the Complaint 

(collectively, the “Seller Aliases”), which were offering for sale and/or selling 

unauthorized and unlicensed products, including clothing and fashion accessories, using 

infringing and counterfeit versions of Dior’s federally registered CHRISTIAN DIOR 

Trademarks, unauthorized copies of the federally registered Dior Copyrighted Designs, or 

both (collectively, the “Unauthorized Dior Products”) to consumers in this Judicial 

District and throughout the United States. 

13. I perform, supervise, and/or direct investigations related to Internet-based infringement of 

the CHRISTIAN DIOR Trademarks and the Dior Copyrighted Designs. Our 

investigation shows that Defendants are using the Seller Aliases to sell Unauthorized Dior 

Products from foreign countries such as China to consumers in the U.S. and elsewhere. I, 

or someone working under my direction, analyzed each of the e-commerce stores 

operating under the Seller Aliases and determined that Unauthorized Dior Products were 

being offered for sale to residents of the United States, including Illinois residents. This 

conclusion was reached through visual inspection of the products listed for sale on each ecommerce store, the price at which the Unauthorized Dior Products were offered for sale, 

other features commonly associated with websites selling counterfeit products, and 

because Defendants and their e-commerce stores do not conduct business with Dior and 

do not have the right or authority to use the CHRISTIAN DIOR Trademarks or copy the 

Dior Copyrighted Designs for any reason. In addition, each e-commerce store offered 

shipping to the United States, including Illinois. Dior also conducted searches of the 

public WhoIs information regarding the Domain Names and identified the provided e1

 The e-commerce store urls are listed on Schedule A to the Complaint under the Online Marketplaces 

and Domain Names. 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 12 of 18 PageID #:569
13 

mail addresses for each domain. True and correct copies of screenshot printouts showing 

the active e-commerce stores operating under the Seller Aliases reviewed are attached as 

Exhibit 5, and WhoIs information for the Domain Names is attached as Exhibit 6. 

14. Defendants have targeted sales to Illinois residents by setting up and operating ecommerce stores that target U.S. consumers using one or more Seller Aliases, offer 

shipping to the U.S., including Illinois, accept payment in U.S. dollars and have sold 

Unauthorized Dior Products to residents of Illinois. 

15. Defendants concurrently employ and benefit from substantially similar advertising and 

marketing strategies. For example, Defendants facilitate sales by designing e-commerce 

stores operating under the Seller Aliases so that they appear to unknowing consumers to 

be authorized online retailers, outlet stores, or wholesalers. E-commerce stores operating 

under the Seller Aliases appear sophisticated and accept payment in U.S. dollars via credit 

cards, Alipay, Amazon Pay, Western Union and/or PayPal. E-commerce stores operating 

under the Seller Aliases often include content and images that make it very difficult for 

consumers to distinguish such stores from an authorized retailer. Dior has not licensed or 

authorized Defendants to use any of the CHRISTIAN DIOR Trademarks or copy the Dior 

Copyrighted Designs, and none of the Defendants are authorized retailers of genuine Dior 

Products. 

16. Many Defendants also deceive unknowing consumers by using the CHRISTIAN DIOR 

Trademarks without authorization within the content, text, and/or meta tags of their online 

stores in order to attract various search engines crawling the Internet looking for websites 

relevant to consumer searches for Dior Products. Other e-commerce stores operating 

under Seller Aliases omit using CHRISTIAN DIOR Trademarks in the item title to evade 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 13 of 18 PageID #:570
14 

enforcement efforts while using strategic item titles and descriptions that will trigger their 

listings when consumers are searching for Dior Products. 

17. On information and belief, Defendants have engaged in fraudulent conduct when 

registering the Seller Aliases by providing false, misleading and/or incomplete 

information to Internet based e-commerce platforms. On information and belief, certain 

Defendants have anonymously registered and maintained Seller Aliases to prevent one 

from learning their true identities and the scope of their e-commerce operation. 

18. On information and belief, Defendants regularly register or acquire new seller aliases for 

the purpose of offering for sale and selling Unauthorized Dior Products. Such seller alias 

registration patterns are one of many common tactics used by the Defendants to conceal 

their identities and the full scope and interworking of their counterfeiting operation, and 

to avoid being shut down. 

19. Even though Defendants operate under multiple fictitious aliases, the e e-commerce stores 

operating under the Seller Aliases often share unique identifiers, such as templates with 

common design elements that intentionally omit any contact information or other 

information for identifying Defendants or other Seller Aliases they operate or use. Ecommerce stores operating under the Seller Aliases include other notable common 

features such as use of the same registration patterns, accepted payment methods, checkout methods, keywords, illegitimate search engine optimization (SEO), advertising 

tactics, similarities in price and quantities, the same incorrect grammar and misspellings, 

and/or the use of the same text and images. Additionally, Unauthorized Dior Products for 

sale by the Seller Aliases bear similar irregularities and indicia of being unauthorized to 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 14 of 18 PageID #:571
15 

one another, suggesting that many of the Unauthorized Dior Products may be 

manufactured by and come from a common source and that Defendants are interrelated. 

20. On information and belief, Defendants are in constant communication with each other and 

regularly participate in QQ.com chat rooms and through websites such as 

sellerdefense.cn, kaidianyo.com and kuajingvs.com regarding tactics for operating 

multiple accounts, evading detection, pending litigation, and potential new lawsuits. 

21. Counterfeiters such as Defendants typically operate under multiple Seller Aliases and 

payment accounts so that they can continue operation in spite of Dior’s enforcement 

efforts. On information and belief, Defendants maintain off-shore bank accounts and 

regularly move funds from their financial accounts to off-shore bank accounts outside the 

jurisdiction of this Court to avoid payment of any monetary judgment awarded to Dior. 

22. On information and belief, Defendants are an interrelated group of counterfeiters working 

in active concert to knowingly and willfully manufacture, import, distribute, offer for sale, 

and sell Unauthorized Dior Products in the same transaction, occurrence, or series of 

transactions or occurrences. Defendants, without any authorization or license from Dior, 

have jointly and severally, knowingly and willfully used and continue to use the 

CHRISTIAN DIOR Trademarks and/or copy the Dior Copyrighted Designs in connection 

with the advertisement, distribution, offering for sale, and sale of Unauthorized Dior 

Products into the United States and Illinois over the Internet. 

23. Monetary damages cannot adequately compensate Dior for ongoing infringement because 

monetary damages fail to address the loss of control of and damage to Dior’s reputation 

and goodwill. Furthermore, monetary damages are difficult, if not impossible, to 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 15 of 18 PageID #:572
16 

ascertain due to the inability to calculate measurable damage in dollars and cents caused 

to Dior’s reputation and goodwill by acts of infringement. 

24. Dior’s goodwill and reputation are irreparably damaged when CHRISTIAN DIOR 

Trademarks are used in connection with the offering for sale or sale of goods not 

authorized, produced, or manufactured by Dior. Dior’s goodwill and reputation are also 

irreparably damaged when the Dior Copyrighted Designs are reproduced, distributed, and 

displayed to the public without permission. Moreover, brand confidence is damaged, 

which can result in a loss of future sales and market share. The extent of harm to Dior’s 

reputation and goodwill and the possible diversion of customers due to loss in brand 

confidence are largely unquantifiable. 

25. Dior is further irreparably harmed by the unauthorized use of the CHRISTIAN DIOR 

Trademarks and Dior Copyrighted Designs because counterfeiters take away Dior’s 

ability to control the nature and quality of the Unauthorized Dior Products. Loss of 

quality control over goods offered for sale or sold under the CHRISTIAN DIOR 

Trademarks or that copy the Dior Copyrighted Designs and, in turn, loss of control over 

our reputation is neither calculable nor precisely compensable. 

26. The use of the CHRISTIAN DIOR Trademarks in connection with the offering for sale or 

sale of goods not authorized, produced, or manufactured by Dior is likely causing and will 

continue to cause consumer confusion, which weakens Dior’s brand recognition and 

reputation. Consumers who mistakenly believe that the Unauthorized Dior Products he or 

she has purchased originated from Dior will come to believe that Dior offers low-quality 

products. Inferior quality products will result in increased skepticism and hesitance in 

consumers presented with genuine Dior Products, resulting in a loss or undermining of 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 16 of 18 PageID #:573
17 

Dior’s reputation and goodwill. Indeed, there is damage to Dior’s reputation and 

goodwill even if a consumer knows that the goods he or she is purchasing are counterfeit. 

Prospective consumers who see inferior Unauthorized Dior Products worn by others may 

mistakenly believe such goods to be genuine and may consequently develop a poor 

impression of Dior and the CHRISTIAN DIOR Trademarks. Such post-sale confusion 

results in damage to Dior’s reputation and correlates to a loss of unquantifiable future 

sales. 

27. Dior is further irreparably damaged due to a loss of exclusivity. Dior Products are meant 

to be exclusive. Dior’s extensive marketing and innovative designs are aimed at growing 

and sustaining sales. The CHRISTIAN DIOR Trademarks and Dior Copyrighted Designs 

are distinctive and signify to consumers that the products originate from Dior and are 

manufactured to Dior’s high quality standards. When counterfeiters use the CHRISTIAN 

DIOR Trademarks and/or copy the Dior Copyrighted Designs to offer for sale or sell 

goods without Dior’s authorization, the exclusivity of Dior’s products, as well as Dior’s 

reputation, are damaged and eroded, resulting in a loss of unquantifiable future sales. 

28. Dior will suffer immediate and irreparable injury, loss, or damage if an ex parte

Temporary Restraining Order is not issued in accordance with Federal Rule of Civil 

Procedure 65(b)(1). 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 17 of 18 PageID #:574
18 

Executed this the 16th day of April 2020 at Paris, France. 

 

 _____________________________________ 

 Nicolas Lambert 

Case: 1:20-cv-02421 Document #: 17 Filed: 04/23/20 Page 18 of 18 PageID #:575