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 Justin R. Gaudio 

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DECLARATION OF JUSTIN R. GAUDIO 

I, Justin R. Gaudio, of the City of Chicago, in the State of Illinois, declare as follows: 

1. I am an attorney at law, duly admitted to practice before the Courts of the State of Illinois 

and the United States District Court for the Northern District of Illinois. I am one of the 

attorneys for Plaintiff Christian Dior Couture, S.A. (“Plaintiff” or “Dior”). Except as 

otherwise expressly stated to the contrary, I have personal knowledge of the following facts 

and, if called as a witness, I could and would competently testify as follows: 

2. According to the Fiscal Year 2018 U.S. Customs and Border Protection (“CBP”) Intellectual 

Property Seizure Statistics Report, e-commerce sales have resulted in a sharp increase in the 

shipment of unauthorized products into the United States. Exhibit 1. Over 90% of all CBP 

intellectual property seizures were smaller international mail and express shipments (as 

opposed to large shipping containers). Id. Over 85% of CBP seizures originated from 

mainland China and Hong Kong. Id. A true and correct copy of an excerpt of this report is 

attached hereto as Exhibit 1. 

3. According to a report released by the U.S. Chamber of Commerce Global Intellectual 

Property Center (GIPC) titled Measuring the Magnitude of Global Counterfeiting, at least 86 

percent of all global counterfeit products originate in Chinese and Hong Kong markets. A 

true and correct copy of an article released by GIPC summarizing the report is attached 

hereto as Exhibit 2. 

4. A February 2017 report commissioned by Business Action to Stop Counterfeiting and Piracy 

(BASCAP) and the International Trademark Association (INTA) entitled The Economic 

Impacts of Counterfeiting and Piracy included findings that counterfeit and pirated products 

account for billions in economic losses, resulting in tens of thousands of lost jobs for 

Case: 1:20-cv-02421 Document #: 16 Filed: 04/23/20 Page 2 of 3 PageID #:421
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legitimate businesses and broader economic losses, including lost tax revenue. A true and 

correct copy of this report is attached hereto as Exhibit 3. 

5. In my experience in combating online counterfeiting over the last ten years, I have observed 

counterfeiters using a variety of tactics to evade enforcement efforts. Specifically, 

counterfeiters like Defendants in the present case will often register new e-commerce stores 

under new aliases once they receive notice of a lawsuit. 

6. In my experience, once notice of a lawsuit is received, counterfeiters such as Defendants 

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

of this Court. Financial account transaction logs that I have reviewed in previous similar 

cases indicate that counterfeiters transfer and/or attempt to transfer funds to off-shore bank 

accounts outside the jurisdiction of this Court once they have received notice of a lawsuit. 

7. For these reasons, in the absence of an ex parte Order, Defendants could and likely would 

move any assets from accounts in financial institutions subject to this Court’s jurisdiction to 

off-shore accounts. 

8. Exhibit 4 attached hereto is a true and correct copy of the unpublished decisions cited in 

Dior’s Memorandum in Support of the Motion for a Temporary Restraining Order. 

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

foregoing is true and correct. 

Executed on this the 23rd day of April 2020 at Chicago, Illinois. 

 

/s/ Justin R. Gaudio/ 

Justin R. Gaudio 

 Counsel for Christian Dior Couture, S.A. 

Case: 1:20-cv-02421 Document #: 16 Filed: 04/23/20 Page 3 of 3 PageID #:422