CONSENT PRELIMINARY INJUNCTION AND ORDER CONFIRMING SEIZURE

EDWARD M. CHEN, District Judge.

WHEREAS, this action having been commenced by Plaintiff, Chanel, Inc. ("Chanel") against the Defendant, Hsiao Yin Fu a/k/a Nicky Fu a/k/a Nicky Hsaio Yin Fu a/k/a Hsiao Yinfu a/k/a Nicki Hsiao a/k/a Peer Fu, an individual, d/b/a Nicky's d/b/a Nicky's European Fashion (the "Defendant"), alleging inter alia, trademark counterfeiting and trademark infringement, false designation of origin, trademark dilution, common law trademark infringement and common law unfair competition, and breach of contract, and a copy of the Summons, Verified Complaint, Order Granting in Part and Denying in Part Plaintiff's Ex Parte Application for Entry of TRO and Seizure Order, etc.; and Granting Motion for Leave to File Excess Pages, dated May 3, 2016 [DE 23 *SEALED*] (the "Sealed Order"), supporting papers, and Orders issued to date having been served upon the Defendant pursuant to the Sealed Order, and Rule 4, Federal Rules of Civil Procedure:

IT IS STIPULATED, ORDER, ADJUDGED AND DECREED that:

1. This Court has jurisdiction of the subject matter of all counts of this action and over all of the named parties hereto.

2. Chanel is the owner of the following trademarks (the "Chanel Marks") in connection with high quality leather products, including handbags and wallets, jewelry products, clothing products, and sunglasses in connection with the trademarks identified on the attached Schedule "A" (the "Chanel Marks");

3. Defendant and her respective officers, agents, servants, employees, and attorneys, as well as other persons in active concert and participation with Defendant or any such person listed above, without an admission of liability, are hereby restrained and enjoined, pending termination of this action, from:

4. Any third party (1) who is a limited custodian of documents and other evidence that (a) belongs to Defendant or that (b) is in Defendant's possession, custody, or control or (2) who is a custodian with responsibility for maintaining records on behalf of Defendant, being served with a copy of this Order is, to the extent not already done, ordered to preserve any and all records (including electronic) in its possession, custody, or control that are connected with the Defendant's use of the Chanel Marks at issue in this matter. Within five (5) days from the receipt of this Order, to the extent not already done, the third party shall provide Plaintiff's counsel with a sworn affidavit confirming compliance with this Order.

5. The seal in this matter is hereby removed, and the Clerk is instructed to return this file to the public portion of the Court records excluding (i) paragraphs 4, 5, and 6 of the Declaration of Stephen M. Gaffigan in Support of Plaintiff's Emergency Ex Parte Application, together with Exhibit 3 to that declaration, and (ii) Exhibit "1" — the Confidential Settlement Agreement — attached to the Verified Complaint and the First Amended Complaint which must remain permanently under seal due to the terms and requirements of the Confidential Settlement Agreement; IN SHORT, THE CLERK SHALL LIFT THE SEALING OF THIS MATTER BUT DOCKET NOS. 1, 28, 6, AND 6-3 SHALL OF FILED UNDER SEAL. PLAINTIFF SHALL PUBLICLY FILE REDACTED COPIES OF DOCKET NOS. 1, 28, 6, AND 6-3 FORTHWITH.

6. The seizure effected on May 4, 2016 pursuant to this Court's Order is hereby confirmed, EXCEPT THAT PLAINTIFF SHALL ADDRESS WHY THE SEIZURE THAT WAS EFFECTED EXCEEDED THE SCOPE OF THE COURTS SEIZURE ORDER, EVEN AFTER PLAINTIFF WAS INFORMED THAT THE COURT WOULD NOT EXPAND THE SEIZURE ORDER. PLAINTIFF SHALL RESPOND BY MAY 26, 2016.

IT IS SO ORDERED.

SCHEDULE A

Trademark Registration Registration Class(es)/Goods Number Date CHANEL 0,626,035 May 1, 1956 IC 18 — Women's handbags CHANEL 1,733.051 November 17, IC 18 — Leather goods; namely, 1992 handbags, wallets, travel bags, luggage, business and credit card cases, change purses, tote bags, cosmetic bags sold empty, and garments bags for travel IC 18 — Leather goods: namely, 1,734,822 November 24, handbags, wallets, travel bags, 1992 luggage, business card cases, change purses, tote bags, and cosmetic bags sold empty 3,025.394 December 13, 2005 IC 18 — Handbags IC 06 — Keychains IC 14 — Costume jewelry 1.501,898 August 30, IC 16 — Gift Wrapping Paper 1988 IC 25 — Blouses, Shoes, Belts, Scarves, Jackets, Men's Ties IC 26 — Brooches and Buttons for Clothing IC 25 — Clothing; namely, coats, jackets, dresses, tops, blouses, 4,241.822 November 13, sweaters, cardigans, skirts. vests, 2012 pants, jeans, belts, swim wear, pareos, beach cover-ups, hats. sun visors, scarves, shawls, ties, gloves, footwear, hosiery and socks