2022-cv-01410

COMPLAINT filed by Peanuts Worldwide LLC; Filing fee $ 402, receipt number 0752-19255767.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Peanuts Worldwide LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Peanuts Worldwide LLC

Notice of Claims Involving Trademarks by Peanuts Worldwide LLC

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Isaku Begert

ATTORNEY Appearance for Plaintiff Peanuts Worldwide LLC by Marcella Deshonda Slay

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (jk2,) (Text entry; no document attached.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

(Trasdemarks)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff Peanuts Worldwide LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Peanuts Worldwide LLC in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Carrie J. Dumont regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Peanuts Worldwide LLC Exhibit 4 - Parts 1 - 3 regarding declaration 16

Exhibit 4-1

Exhibit 4-2

(Exhibit 4-3)

MOTION by Plaintiff Peanuts Worldwide LLCfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Peanuts Worldwide LLC in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Martha M. Pacold: For the reasons set forth in the motions 3, 13, 18 filed by plaintiff Peanuts Worldwide LLC, the supporting memoranda 14, 18, and the temporary restraining order, plaintiff's motions for leave to file under seal 3, electronic service of process 18, and for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13 are granted. Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, were defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a substantial likelihood of success on the merits (including evidence of active infringement and sales into Illinois), the harm to plaintiff is irreparable, and an injunction is in the public interest. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendants. As other judges in this district have noted, there may be reason to question both the propriety of the joinder of all defendants in this one action and whether plaintiff genuinely intends to pursue an accounting, but at this preliminary stage, plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. If any defendant appears and objects, the court will revisit the asset freeze and joinder. Plaintiff shall deposit with the Clerk of Court ten thousand dollars ($10,000.00), either cash or surety bond, as security.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Martha M. Pacold on 3/25/2022:

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A" (Text entry; no document attached.)

MOTION by Plaintiff Peanuts Worldwide LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Peanuts Worldwide LLC in support of extension of time[23]

Declaration of Isaku M. Begert

SURETY BOND in the amount of $10,000 posted by Peanuts Worldwide LLC. (Document not scanned).

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's ex parte motion to extend the Temporary Restraining Order 23 is granted. The TRO is extended until 4/22/2022.

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Martha M. Pacold on 4/6/2022:

MOTION by Plaintiff Peanuts Worldwide LLC for preliminary injunction, MOTION by Plaintiff Peanuts Worldwide LLC for extension of time of Temporary Restraining Order

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for preliminary injunction, extension of time[28]

Declaration of Isaku M. Begert

Exhibit 1

SUMMONS Returned Executed by Peanuts Worldwide LLC as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 4/19/2022, answer due 5/10/2022.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Martha M. Pacold: The court has taken the motion for preliminary injunction 28 under advisement and will consider the motion unopposed if no defendant appears and objects by 4/29/2022. Plaintiff shall serve defendants with this notice. Plaintiff's motion to extend the TRO 28 is granted. For the reasons stated in the Court's orders entering and extending the TRO, as well as in Plaintiff's earlier motion 23 to extend the TRO, the TRO is further extended to and including the date on which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844.

MINUTE entry before the Honorable Martha M. Pacold: No defendant has appeared or filed an objection to the motion for preliminary injunction [28]. A preliminary injunction is appropriate for the same reasons a TRO was granted, and is unopposed. Plaintiff's motion for preliminary injunction [28] is granted. Enter Preliminary Injunction. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Martha M. Pacold on 5/9/2022:

ORDER: The Clerk is directed to unseal any previously sealed documents in this matter. Signed by the Honorable Martha M. Pacold on 5/9/2022. Mailed notice

NEW PARTIES: Yiwu Ken Jewelry Co.,ltd, Zhuji Hewei Socks Co., Ltd., Zhuji Hongjin Knitting Co., Ltd., Zhuji Hongrun Import And Export Co., Ltd., Yiwu Panrun Commodity Factory, Zhejiang Xiyoumi Textile Tech Co., Ltd., Shenzhen Yisen Electronics Co., Ltd, Yiwu Haodong Electronic Commerce Co., Ltd., Yiwu Lanwan E-Commerce Co., Ltd., Shop1100005092 Store, Shop1100006086 Store, Shop1100011092 Store, Shop1100151281 Store, woyang Store, TShirley happiness Store, Nananano Store, CC Wong Store, hai xin Store, TPE01 Store, Shop5786570 Store, Doublefeet Store, Toy Discount Store, YY Electrical Store, ABD Toy Store, Shop911549061 Store, SiYao plush toy Store, Situke Cases Store, STK Baby Cases Store, Noveltys Toy Store, Personalized mobile phone accessories Store, LAIFUSHOP001 Store, TopGood Store, YANR Toy Store, LU Wood Store, fengfu Store, OneAndOne Store, Hisinside Store, K&Stationery Store, YingYingtoys Store, zhangnine Store, Digital Boutique Store, Friendly Decal Store, mu mian Store, Shop912624855 Store, Shop912625537 Store, KKM cotton Store, A litter Store, Kids-Pajamas Store, xuchanglunxuanshangmaoyou, Wdzbh, lifujuna, Vicetion US, JinYuan maoyi, MINGYU66, youqingriyong, xuyang37, guangzhoujiansuishangmao, qunbin09, Getting Better T, YANAG, huangyonghao123, Lambert Dillon, HQYKJ, liuyixinrui, junyao2, haofengqindedian, Lemai ForeveR, Linyi Dongfang Juli Trading Co., Ltd., A1TRCYF76M6T7R, XQYYbaihuo, zhong xin rong, PANGPANGKEJI, LMRLETB, heyanyan, MiLan998, hongyuanxinrong, aopeng1819, Xudeiqiang's Shop, critic, LIN CHEN ZHI, LISHENG US, HLXBWM US, USA YAA, A HA MA, Xianshusiruanjiankejiyouxian, Qinghao Maoyi, w2018, Woyenfen, HUIDU DECOR, Lin Xian Cheng Zhuang Xiao Lei Ri Za Dian, FireFireWaterMercury, shuxianjingxiao, ChuangTuDianZi, GYPUS, shenglongjixie, YI BO TE, tunanriyongpindian, fefewfde, maoduodianzi, zxzvsdsdf, YangYangRiYongBaiHuo, ZoZo store, Better box, jing luo, JHMYSH, huxialin, Eleganthouse, ZhaoYuBH, lianyungangsangemaoyiyouxiangongsi, luyalide, US Christmas Gifts Brand, cheng83, tanduolv, feilo0ngli, YI LAI LI, Okworld, A3JVTMJTAU5BOM, NewMoonerone, shilanlanzz, beianshitaiyueyunshuyouxiangongsi., xiaochaoyanxuanriyongbaihuodian, auxiuxia, QuYun Xiang Bai Huo Jing Ying Bu, YONG ZE US, ScharnhorstSchlachtkreuzer, SXBRTM, li wenxiangli wenxiang, JieTan, Lorena LTD, Htxxxx, MIRANDA INTERNATIONAL TRADE LIMITED sagdsag, yuxilinxidianzishangwuyouxianzerengongsi, luo hang, HanLuo, wyjUsa-shop, comfortable rock, LIUCHUNLING, DuoPan Store, Candy Shi, hdgfuyw, Jack Hong, xu zhou xin ru dian zi shang wu you xian gong si, homefash, KeShaobao Art, Shenqiangshangmao, SHUOZHUO, ChengDuXinWenYiYaShangMaoYouXianGongSi, guangzhouminsaishangmaozhongxi, cute baby doll, householdproducts1 Store, DISMISSED, Dianqiy INC, CESOD, Muswanna, Anthea LLC, NO. 1 store in China, liukesong, DH Shoping, GHDJYRfghr, hrd;to;FLGARE, mashuli jhgh5, jiangmingshop, chenxuejiao8571, yuanguoyun, gaoqiuhong shop, IndulgeinlovesB, Debra Williams, tnmshop, Deng wen yuan shop, LTR1314520, Deng xiao ting shop, zhangyuchengkjb, WangYunLanshop, Lixiaoyanshop, ghdrgkhrlt, Eslum and Fyeklant added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint 35 is granted. Defendants Linyi Dongfang Juli Trading Co., Ltd., maoduodianzi, and Dehktigger are hereby dismissed. Defendant's motion for leave to amend Schedule A to the complaint instanter 37 is granted. Defendants ZoZo store, and Shenqiangshangmao are hereby dismissed.

MOTION by Plaintiff Peanuts Worldwide LLC for Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Amended Schedule A

MOTION by Plaintiff Peanuts Worldwide LLC for entry of default, MOTION by Plaintiff Peanuts Worldwide LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Peanuts Worldwide LLC in support of motion for entry of default, motion for default judgment[42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint 40 is granted. Defendants USA YAA and ChengDuXinWenYiYaShangMaoYouXianGongSi are hereby dismissed. Any defendant objecting to Plaintiff's motion for entry of default and default judgment 42 must enter an appearance and file a written objection by 6/7/2022. If no objections are filed, the court will consider the motion unopposed. Plaintiff shall serve defendants with this notice.

ATTORNEY Appearance for Defendants Anthea LLC, Dianqiy INC by Adam Edward Urbanczyk

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Amended Schedule A

MOTION by Defendants Anthea LLC, Dianqiy INC for extension of time

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint [47] is granted. Defendant Muswanna is hereby dismissed. Defendants Dianqiy INC and Anthea LLC's motion for extension of time [49] is granted. Defendants answer to the complaint and any objections to Plaintiff's motion for entry of default and default judgment [42] is due by 6/27/2022.

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Amended Schedule A

ATTORNEY Appearance for Defendant sqy_wmus by Adam Edward Urbanczyk

MOTION by Defendant sqy_wmus for extension of time

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint [51] is granted. Defendants LIN CHEN ZHI and Okworld are hereby dismissed. Defendant sqy_wmus's motion for extension of time [54] is granted. Defendant sqy_wmus's answer to the complaint and any objections to Plaintiff's motion for entry of default and default judgment [42] are due by 7/7/2022.

ATTORNEY Appearance for Defendant CESOD by Adam Edward Urbanczyk

MOTION by Defendants Anthea LLC, CESOD, Dianqiy INC, sqy_wmus for extension of time UNOPPOSED in part

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Amended Schedule A

MINUTE entry before the Honorable Martha M. Pacold: The unopposed motion for extension of time filed by defendants Anthea LLC, Dianqiy INC, and sqy_wmus a/k/a CESOD [57] is granted. Anthea LLC's and Dianqiy INC's answers to the complaint and any objections to Plaintiff's motion for entry of default and default judgment [42] are due by 7/15/2022. CESOD's answer to the complaint and any objections to Plaintiff's motion for entry of default and default judgment is due by 7/7/2022.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint [58] is granted. Defendant Zhejiang Xiyoumi Textile Tech Co., Ltd. is hereby dismissed.

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Amended Schedule A

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint [62] is granted. Defendant Zhuji Hewei Socks Co., Ltd. is hereby dismissed.

MOTION by Plaintiff Peanuts Worldwide LLCfor Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit[2] Instanter

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint 65 is granted. Defendants CESOD and Anthea LLC are hereby dismissed.

MINUTE entry before the Honorable Martha M. Pacold: The deadline for defendant Dianqiy INC to answer the complaint and pending motion for entry of default and default judgment was 7/7/2022. [60]. To date, Dianqiy has not filed any answer or response to the motion. The parties are directed to file a joint status report by 8/11/2022 addressing whether Dianqiy intends to file any answer or response. Mailed notice

MOTION by Plaintiff Peanuts Worldwide LLC to approve consent judgment as to a Certain Defendant

STATUS Report Joint per [68] by Peanuts Worldwide LLC

ORDER: Plaintiff's motion for entry of consent judgment [69] is granted. Enter Consent Judgment. All of the defendants who had appeared have now been dismissed. Plaintiff's motion for entry of default and default judgment [42] against the remaining defendants who have not appeared and objected is treated as unopposed and therefore granted. The ten thousand dollars ($10,000) surety bond posted by plaintiff is hereby released to plaintiff's counsel. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to plaintiff's counsel Amy Crout Ziegler at Greer, Burns & Crain, Ltd., 300 S. Wacker Dr., Suite 2500, Chicago, IL 60606, via certified mail. Enter Final Judgment Order. Terminate civil case. Signed by the Honorable Martha M. Pacold on 8/18/2022. Mailed notice

CONSENT JUDGMENT. Signed by the Honorable Martha M. Pacold on 8/18/2022. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Martha M. Pacold on 8/18/2022. Mailed notice

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Peanuts Worldwide LLC. Amy Crout Ziegler at Greer, Burns & Crain, Ltd., 300 S. Wacker Dr., Suite 2500, Chicago, IL 60606 via certified mail # 7021 1970 0001 3330 0601. (Text entry; no document attached.)

FULL SATISFACTION of Judgment regarding order[73] in the amount of $500,000 as to a certain defendant

FULL SATISFACTION of Judgment regarding order[73] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[73] in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[73] in the amount of $500,000 as to certain defendant