2022-cv-03279

COMPLAINT filed by The Mountain Corporation; Jury Demand. Filing fee $ 402, receipt number AILNDC-19587158.

(Exhibit Group Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff The Mountain Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff The Mountain Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff The Mountain Corporation by Robert Payton Mcmurray

MOTION by Plaintiff The Mountain Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff The Mountain Corporation Sealed Schedule A

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Mountain Corporation

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.

MOTION by Plaintiff The Mountain Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff The Mountain Corporation for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by The Mountain Corporation in support of motion for temporary restraining order, 10

Declaration Doyon Declaration

Exhibit Group Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 1 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 2 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 3 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 4 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 5 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 6 of Doyon Declaration

SEALED DOCUMENT by Plaintiff The Mountain Corporation Exhibit 2 Part 7 of Doyon Declaration

Notice of Claims Involving Trademarks by The Mountain Corporation

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 10 before Honorable Jorge L. Alonso on 6/30/2022 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 6 is granted. Plaintiff's motion to exceed page limitation 9 is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the Defendant domain names, a temporary asset restraint, expedited discovery and service of process by email and/or electronic publication 10 is granted. Enter Sealed Temporary Restraining Order. Telephonic status hearing set for 7/13/22 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 6/30/2022. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing previously set for 7/13/22 at 9:30 a.m. is reset to 7/13/22 at 9:00 a.m. TIME CHANGE ONLY. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MOTION by Plaintiff The Mountain Corporation for extension of time Plaintiff's Ex Parte motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 7/26/22 at 9:30 a.m. Plaintiff's ex-parte motion to extend the temporary restraining order [26] is granted. The temporary restraining order is extended for 14 days to 7/27/22. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

SURETY BOND in the amount of $ 10,000.00 posted by The Mountain Corporation. (Document not scanned)

MOTION by Plaintiff The Mountain Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by The Mountain Corporation in support of motion for preliminary injunction[29]

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction[29]

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction[29] before Honorable Jorge L. Alonso on 7/26/2022 at 09:30 AM.

MOTION by Plaintiff The Mountain Corporation for extension of time Plaintiff's Ex Parte motion to Extend the Temporary Restraining Order

Exhibit 1

Exhibit 2

SUMMONS Returned Executed by The Mountain Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 7/21/2022, answer due 8/11/2022.

PRO SE Appearance by Defendant Xu Jiahao.

MOTION by Defendant Xu Jiahao to dismiss Plaintiff's Complaint [Dkt 1 ] and Deny Plaintiff's Motion For Preliminary Injunction [Dkt 29 ] and Extension[Dkt 33 ].

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/9/22 at 9:30 a.m. Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 29 is denied without prejudice. Plaintiff's ex parte motion to extend the temporary restraining order as to certain Defendants 33 is granted as to all Defendants. The temporary restraining order is extended through 8/10/22. Plaintiff's response to Defendant's motion to dismiss Plaintiff's complaint [dkt 1] and deny Plaintiff's motion for preliminary injunction [dkt 29] and extension [dkt 33] 36 shall be filed by 8/16/22; Defendant's reply shall be filed by 8/30/22. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

MOTION by Plaintiff The Mountain Corporation for preliminary injunction Plaintiff's Renewed Motion for Entry of a Preliminary Injunction

MEMORANDUM by The Mountain Corporation in support of motion for preliminary injunction 38

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 38

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 38 before Honorable Jorge L. Alonso on 8/9/2022 at 09:30 AM.

SUMMONS Returned Executed by The Mountain Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 8/4/2022, answer due 8/25/2022.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 9/28/22 at 9:30 a.m. Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's renewed motion for entry of a preliminary injunction [38] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all previously sealed documents. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 8/9/2022. Notice mailed by Judge's staff

NEW PARTIES: 85635986, a3344, chuwentao158, guoyonggang16751, jihonghu29551, jincaizeng61235, liguangyun21375, liuxinying42423, lixiaowei21037, lvyingying153, meiwenhui0623, MelissaHeatherbPrLr, sunhongyan1612, sunjie48974, sunyuyang3519, wangdan4483, wanghanyu9401, wangxiuzhen7890, xuyuehui3214, yangcangning112022, zdy476803, zengli1006, zhangjingying0667, zhangjunyuan4469, zhangxiaolan31080, zhanhxianfang5201314, zhaojingyan190306, zhaokai76353, zhaoli97780, zhaozikang65511, zhengjie07313, zhongwenhui Store, zhoutian422322, 012 Store, 09 Store, 100% cotton 13 Store, 100% cotton printing 08 Store, 100% cotton tshirs.00001 Store, 100% cotton T-shirt 044 Store Store, 100% cotton T-shirt 35 Store, 100% cotton T-shirt 46 Store, 100% cotton T-shirt 47 Store, 100% cotton T-shirt 51 Store, 100% cotton T-shirt 57 Store, 100% cotton tshirts 000888 Store, 100% Cotton T-shirts 30 Store, 100% Cotton T-shirts DD Store, 100% Cotton T-shirts L Store, 100% Cotton T-shirts PP Store, 100% cotton tshirts. Store, 100% cotton tshirts666 Store, 100%cotton men women Tshirt Store, 100%cotton Tshirt old Store, 131781316382 Store, 667788 Store, 98787eDSDFCC Store, Bienvenue Store, chogless Store, cotton T-shirt 666 Store, cotton T-shirt 77 Store, Cotton T-shirts B Store, Cotton T-shirts L Store, Cotton T-shirts X Store, DASHANG Store, F102 Store, F34 Store, hotting tshirt store 15124 Store, it tshirt S Store, kaikai888 Store and KDH9 Store added to case caption.

NEW PARTIES: KHL Store, shop 5843624 Store, Shop910451209 Store, Shop910456150 Store, Shop910562383 Store, Shop910568352 Store, Shop910721088 Store, Shop911039141 Store, Shop911056220 Store, Shop911297060 Store, Shop911414191 Store, Shop911547093 Store, ShopAliaeAbnewfuture Store, ShopAliaeBbnewfuture Store, ShopAliaeBdnewfuture Store, ShopAliaeDfnewfuture Store, tqianqian Store, T-shirt 05 Store, T-shirt 07 Store, tshirts.00002 Store, Very good T-shirt 196 Store, Very good T-shirt 209 Store, Very good T-shirt yy Store, chenchunhui9424, HaleLambertiYsTm, hsvig55shop, hushuqiang Store, huxiuli123456, huzhiqiu123, jianghuajiang2584, JuliusAndrewuCuNk, lihuiru76230, lijiamei147, liting3658, liuchang5746, liujiaming3815, liyuefei21, longfei Store me, lxlaksdbuizxbcn, mengfanwei66058, mengfuasdsf, NicoleBessfHgG, nyvfhnbes, Olin William, RalapEvanjDjD, taofuwen29030, vbmcfgherw, xuhuimei54768, xulijie Store, yangfenglai Store, Yantianj, yuelei23465, Z Men, zhangli81726, zhangn268682, zhangpei163, zhangpengjja, zhangshilei47329, zhangsong373664, zhangweihua Store, zhangxiuxia856356, zhangyulin88, zhaodonggang6895, zhaohui01234, zhaojian01670, zhaojiangqian Store, zhaorulong Store, zhengshan Store me, zhenxiaojie2618, Zhezheknittingshop, zhoujiyong66058, zhoutiantian62687, zhouyawei5616, zhuminggang17798, zhushuangsu66058, zhuxiaolong1234, zhuyongjian Store, zhuyuxiang66058, ZLmetals and Bonnie Hokjge added to case caption.

RESPONSE by Plaintiff The Mountain Corporation Plaintiff's Response to Defendant's Motion to Dismiss

Exhibit A

Exhibit B

(Exhibit C)

MOTION by Defendant Xu Jiahao to withdraw its motion 36

NEW PARTIES: 85635986, a3344, chuwentao158, guoyonggang16751, jihonghu29551, jincaizeng61235, liguangyun21375, liuxinying42423, lixiaowei21037, lvyingying153, meiwenhui0623, MelissaHeatherbPrLr, sunhongyan1612, sunjie48974, sunyuyang3519, wangdan4483, wanghanyu9401, wangxiuzhen7890, xuyuehui3214, yangcangning112022, zdy476803, zengli1006, zhangjingying0667, zhangjunyuan4469, zhangxiaolan31080, zhanhxianfang5201314, zhaojingyan190306, zhaokai76353, zhaoli97780, zhaozikang65511, zhengjie07313, zhongwenhui Store, zhoutian422322, 012 Store, 09 Store, 100% cotton 13 Store, 100% cotton printing 08 Store, 100% cotton tshirs.00001 Store, 100% cotton T-shirt 044 Store Store, 100% cotton T-shirt 35 Store, 100% cotton T-shirt 46 Store, 100% cotton T-shirt 47 Store, 100% cotton T-shirt 51 Store, 100% cotton T-shirt 57 Store, 100% cotton tshirts 000888 Store, 100% Cotton T-shirts 30 Store, 100% Cotton T-shirts DD Store, 100% Cotton T-shirts L Store, 100% Cotton T-shirts PP Store, 100% cotton tshirts. Store, 100% cotton tshirts666 Store, 100%cotton men women Tshirt Store, 100%cotton Tshirt old Store, 131781316382 Store, 667788 Store, 98787eDSDFCC Store, Bienvenue Store, chogless Store, cotton T-shirt 666 Store, cotton T-shirt 77 Store, Cotton T-shirts B Store, Cotton T-shirts L Store, Cotton T-shirts X Store, DASHANG Store, F102 Store, F34 Store, hotting tshirt store 15124 Store, it tshirt S Store, kaikai888 Store and KDH9 Store added to case caption.

NEW PARTIES: KHL Store, shop 5843624 Store, Shop910451209 Store, Shop910456150 Store, Shop910562383 Store, Shop910568352 Store, Shop910721088 Store, Shop911039141 Store, Shop911056220 Store, Shop911297060 Store, Shop911414191 Store, Shop911547093 Store, ShopAliaeAbnewfuture Store, ShopAliaeBbnewfuture Store, ShopAliaeBdnewfuture Store, ShopAliaeDfnewfuture Store, tqianqian Store, T-shirt 05 Store, T-shirt 07 Store, tshirts.00002 Store, Very good T-shirt 196 Store, Very good T-shirt 209 Store, Very good T-shirt yy Store, chenchunhui9424, HaleLambertiYsTm, hsvig55shop, hushuqiang Store, huxiuli123456, huzhiqiu123, jianghuajiang2584, JuliusAndrewuCuNk, lihuiru76230, lijiamei147, liting3658, liuchang5746, liujiaming3815, liyuefei21, longfei Store me, lxlaksdbuizxbcn, mengfanwei66058, mengfuasdsf, NicoleBessfHgG, nyvfhnbes, Olin William, RalapEvanjDjD, taofuwen29030, vbmcfgherw, xuhuimei54768, xulijie Store, yangfenglai Store, Yantianj, yuelei23465, Z Men, zhangli81726, zhangn268682, zhangpei163, zhangpengjja, zhangshilei47329, zhangsong373664, zhangweihua Store, zhangxiuxia856356, zhangyulin88, zhaodonggang6895, zhaohui01234, zhaojian01670, zhaojiangqian Store, zhaorulong Store, zhengshan Store me, zhenxiaojie2618, Zhezheknittingshop, zhoujiyong66058, zhoutiantian62687, zhouyawei5616, zhuminggang17798, zhushuangsu66058, zhuxiaolong1234, zhuyongjian Store, zhuyuxiang66058, ZLmetals and Bonnie Hokjge added to case caption.

NEW PARTIES: chengweich, C-YDRAGON, fhxhjhhthb, FsaYIX, GaoMingHui, JOOLSSUN, lucksupers, Moxiu, shanxishihengkeoujianzhugongchengyouxiangongsi, shanxisupiaodianzishangwuyouxiangongsi, shenzhenshixinyishiyeyouxiangongsi, SHINYOK, sjraoa, sunchaoUS, Szyzsyyxgs, Toomyeen, UJJERYTOW, wnlvio, xianshixinchengquhoNgbianyubaihuodian, yiwushixiehao dianzishangwuyouxiangongsi, yiwushixulingmao yiyouxiangongsi, zaoqiangxianmengbaoshuiguodian, 100% cotton T-shirt 171 Store, 100% cotton T-shirt BM Store, 100% Cotton T-shirts II Store, 100% Cotton T-shirts WW Store, AK008 Store, alibb586688good Store, bao li Store, Cotton T-shirt MM Store, Cotton T-shirts F Store, ddsss Store, DHD7 Store, Dongdong short-sleeved 09 Store, gon niu Store, Good design Store, Qinyong Store, shop65465 Store, Shop911088022 Store, shop99900013 Store, Shopper07 Store, Shopper09 Store, Shopper15 Store, Shopper17 Store, Shopper29 Store, Shopper38 Store, ST008 Store, TNT008 Store, wj 03 Store and WT04 Store added to case caption.

MINUTE entry before the Honorable Jorge L. Alonso: Defendant Moxiu's motion to withdraw its motion 36 is granted. Defendant's motion to dismiss Plaintiff's complaint [dkt 1 ] and deny Plaintiff's motion for preliminary injunction [dkt 29 ] and extension [dkt 33 ] 36 is withdrawn. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by The Mountain Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No.158

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 11/10/22 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

DECLARATION of William B. Kalbac Declaration of Service

MOTION by Plaintiff The Mountain Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

MEMORANDUM by The Mountain Corporation in support of motion for default judgment 51

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 51

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment 51 before Honorable Jorge L. Alonso on 11/10/2022 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against the Defendants identified in amended schedule A 51 is granted. Enter Final Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL JUDGMENT ORDER. Signed by the Honorable Jorge L. Alonso on 11/10/2022. Notice mailed by Judge's staff