Chrome Hearts (“CH”) owns some of the most famous trademarks (“Marks”) in the luxury industry. These trademarks are used to identify, advertise, and promote Chrome Hearts products, activities, and services. A great deal of time and effort has gone into developing the goodwill surrounding the Marks and that the Marks have a secondary meaning in the mind of the public. The Marks are protected around the world under U.S. and international trademark laws.