2022-cv-03350

COMPLAINT filed by Nike, Inc.; Filing fee $ 402, receipt number AILNDC-19599037.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Nike, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Nike, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Nike, Inc.

Notice of Claims Involving Trademarks by Nike, Inc.

ATTORNEY Appearance for Plaintiff Nike, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Nike, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Nike, Inc. by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff Nike, Inc. 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. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

Trademarks

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

MOTION by Plaintiff Nike, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Nike, Inc. 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 Joe Pallett regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-10 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

(Exhibit 3-10)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 11-15 regarding declaration 16

Exhibit 3-11

Exhibit 3-12

Exhibit 3-13

Exhibit 3-14

(Exhibit 3-15)

MOTION by Plaintiff Nike, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Nike, Inc. in support of motion for miscellaneous relief 19

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 20

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Gary Feinerman:Motions [3], [13] and [19] are entered and continued to 7/11/2022 at 9:00 a.m. Attorneys/Parties should appear for the 7/11/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

ATTORNEY Appearance for Plaintiff Nike, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Nike, Inc. by Allyson M. Martin

MINUTE entry before the Honorable Gary Feinerman:Motion hearing held. Status hearing set for 7/26/2022 at 9:15 a.m. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 3, Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, motion for electronic service of process 19 are granted. Enter sealed TRO. Attorneys/Parties should appear for the 7/26/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

MINUTE entry before the Honorable Gary Feinerman:The status hearing set for 7/26/2022 at 9:15 a.m. [25] is re-set for 9:00 a.m. TIME CHANGE ONLY. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

MOTION by Plaintiff Nike, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Nike, Inc. in support of extension of time[28]

Declaration of Jake M. Christensen

MINUTE entry before the Honorable Gary Feinerman:Motion for extension of time 28 is granted. The TRO 26 is extended to 8/8/2022 at Noon CT. The status hearing set for 7/26/2022 27 is stricken and re-set for 8/8/2022 at 9:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Nike, Inc. (Document not scanned)

MINUTE entry before the Honorable Gary Feinerman: The status hearing set for 8/8/2022 is stricken and advanced to 8/4/2022 at 9:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice

MOTION by Plaintiff Nike, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[33]

Declaration of Jake M. Christensen

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/1/2022, answer due 8/22/2022.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Gary Feinerman:Motion for preliminary injunction [33] is entered and continued to 8/4/2022 at 9:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

MOTION by Defendant iYYVV to dismiss plaintiff's complaint and deny plaintiff's motion for preliminary injunction.

MINUTE entry before the Honorable Gary Feinerman:Status hearing held and continued to 9/20/2022 at 9:00 a.m. Motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [33] is granted. Enter preliminary injunction order. Defendant iYYVV's motion to dismiss and to vacate preliminary injunction [37] is entered and continued. Plaintiff shall respond to the motion by 8/10/2022. Motion hearing set for 8/18/2022 at 9:00 a.m. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain, Ltd., 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/instructions. Attorneys/Parties should appear for the 8/18/2022 and 9/20/2022 hearings by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Gary Feinerman on 8/4/2022.Mailed notice.

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MOTION by Plaintiff Nike, Inc. to stay Briefing [38]

Exhibit A

MINUTE entry before the Honorable Gary Feinerman:Motion to amend [40] is granted. The briefing schedule on Defendant iYYVV's motion to dismiss and vacate preliminary injunction [37] is amended as follows: Plaintiff shall respond to the motion by 8/31/2022; Defendant shall reply by 9/15/2022. The motion hearing set for 8/18/2022 [38] is stricken and re-set for 9/20/2022 at 9:00 a.m. Attorneys/Parties should appear for the 9/20/2022 hearings by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Nike, Inc. as to a Certain Defendant

MOTION by Plaintiff Nike, Inc. for entry of default as to all Defendants, MOTION by Plaintiff Nike, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[44]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

MINUTE entry before the Honorable Gary Feinerman:Motion for entry of default and default judgment 44 is entered and continued to 9/20/2022 at 9:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

MINUTE entry before the Honorable Gary Feinerman:Status hearing held and continued to 10/4/2022 at 9:00 a.m. Motion hearing held. For the reasons stated on the record, motion to dismiss 37 is denied as moot. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against all remaining Defendants 44 granted in part (as to the Rule 55(a) entry of default) and entered and continued in part (as to the Rule 55(b) default judgment). Enter Rule 55(a) default as to remaining defendants. If any defendant wishes to oppose Plaintiff's Rule 55(b) motion for default judgment, that defendant should file a written opposition by 10/3/2022 or appear at the 10/4/2022 hearing; otherwise, the court will rule on the Rule 55(b) motion on the papers at the 10/4/2022 hearing. Plaintiffs shall electronically serve a copy of this order on all remaining defendants. Attorneys/Parties should appear for the 10/4/2022 hearing by calling the Toll-Free Number: (877) 336-1828, Access Code: 4082461. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please, please be sure to keep your phone on mute when you are not speaking. 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.Mailed notice.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

MINUTE entry before the Honorable Gary Feinerman:Status hearing held. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 44 is granted. Enter order. Enter judgment order. Civil case closed.Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Gary Feinerman on 10/4/2022.Mailed notice.

ENTERED JUDGMENT on 10/4/2022.Mailed notice.

FULL SATISFACTION of Judgment regarding entered judgment[52] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding entered judgment[52] in the amount of $200,000 as to certain defendant