2022-cv-04879

COMPLAINT filed by Royer Brands International S.A.R.L.; Filing fee $ 402, receipt number BILNDC-19824767.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Royer Brands International S.A.R.L. Schedule A regarding complaint[1]

MOTION by Plaintiff Royer Brands International S.A.R.L. for leave to file under seal

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Royer Brands International S.A.R.L.

Notice of Claims Involving Trademarks by Royer Brands International S.A.R.L.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Benjamin C.R. Lockyer

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Royer Brands International S.A.R.L. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Royer Brands International S.A.R.L. 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 Olivier Mercier regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Royer Brands International S.A.R.L. Exhibit 3 - Parts 1-5 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

(Exhibit 3-5)

MOTION by Plaintiff Royer Brands International S.A.R.L.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Royer Brands International S.A.R.L. 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 Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for telephonic hearing on 9/21/2022 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Justin Tyler Joseph

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 9/21/2022. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] are granted. Enter Sealed Temporary Restraining Order. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2] and (2) Exhibit 3 - Parts 1-5 to the Declaration of Olivier Mercier [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 9/21/2022 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 10/5/2022 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 9/21/2022.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (jk2,)

SURETY BOND in the amount of $ 10,000.00 posted by Royer Brands International S.A.R.L.

MOTION by Plaintiff Royer Brands International S.A.R.L. for extension of time of Temporary Restraining Order

MEMORANDUM by Royer Brands International S.A.R.L. in support of extension of time[25]

Declaration of Marcella D. Slay

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Kahlia Roe Halpern

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 10/5/2022. Plaintiff's ex parte motion to extend the temporary restraining order 25 is granted. The Court finds good cause to extend the temporary restraining order through 10/19/2022 pursuant to Fed. R. Civ. P. 65(b)(2). Telephonic status hearing set for 10/19/2022 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

MOTION by Plaintiff Royer Brands International S.A.R.L. for preliminary injunction

(Exhibit A)

MEMORANDUM by Royer Brands International S.A.R.L. in support of motion for preliminary injunction 30

Declaration of Marcella D. Slay

(Exhibit 1)

SUMMONS Returned Executed by Royer Brands International S.A.R.L. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/14/2022, answer due 11/4/2022.

Declaration of Marcella D. Slay

(Exhibit A)

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Justin Tyler Joseph

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 10/19/2022. Only Plaintiff appears. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [30] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal Schedule A to the complaint [2], Exhibit 3 - Parts 1-5 to the Declaration of Olivier Mercier [17], and the Sealed Temporary Restraining Order [24]. 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 www.ilnd.courts.com/instructions. Telephonic status hearing set for 12/1/2022 at 10:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 10/19/2022. Mailed notice

NEW PARTIES: Fujian Qiha Ha Network Technology Co., Ltd., Guangdong Zebra Jewelry Co., Ltd., Guangzhou Csmei Jewelry Co., Ltd., Shaoxing Jolon Gifts Co., Ltd., Yiwu Wenzhuo E-Commerce Firm, ac0727-luggage-family Store, AK115 Store, BZ Store, CR PATCH Store, DPSDE Sexy Women's Store, dxydecals Store, earlfamily Official Store, Elife Zone Co., Ltd, GEJU Store, green stickers Store, LuckyBeauties Store, MotoPATCHES Official Store, MOTOR PATCH Store, QS car products Store, sexy baby 001 Store, shop 9900024 Store, Shop1100011010 Store, Shop1100171357 Store, Shop1100185102 Store, Shop1100223429 Store, Shop1100250117 Store, Shop1100265004 Store, Shop1100287155 Store, Shop1100351486 Store, Shop1100388939 Store, Shop1100390921 Store, Shop1102056527 Store, Shop1102059999 Store, Shop1102062548 Store, Shop1102094556 Store, Shop1102099016 Store, Shop1188201 Store, shop58426 Store, shop7969 Store, Shop910329021 Store, Shop910942024 Store, Shop910961020 Store, Shop911050120 Store, ST Depp Store, TEEZ Store, you ku Store, zipin Store, A3CIK1Q8GKI004, Bass hat shop, cdb1502102, chen1212jing, chenguoxiong888, kunmingtanghuikejiyouxianzerengongsi, linfubin, linzhiweiddd, LOijasjw582, VCBVGFDSHHFD9GVFDSGHSDFH, XQYECOS, YEGFGH, Zedexi Direct, Aliyun1, Beautiful0001, Beverly888, Caps16, Chanel8888, Chenyu2, Dvhw, elegance01 Store, Elv1s_love88, Fndwia, Followingfrom, hkshenyusheng10 Store, ju_sporting Store, Keaccstore, Laipin, Pfzcta0, Pfzctd2, Polouxie8885, Pxinfu2021, Saifannu, Shupi, Wmgb, Wmomo2, Yuacc2022, gzmotormall, 30 segundos, Alice Patel, Anthony Greens, Archie Ramirez, Arthur Calton, biddlenathan, Breeze cakes and bakery, Brooke Hammons, chenwei582, Cocoban, Connorgetem, danerhcyre, Danielleoo, Deborah Hampton, dingwenbo01429, Earnestyy, Emmayy, FSdfgx, gaokegang Store, Gary Mathis, hanshengnan50817, hdnjshuyfdtu, hechongkai22807, heyao01847, huanglihua Store, I love my home store, James Naquin, jiazihan3, jnffgh, Joseph Garcia, kangjiafu62124, kduiurkjher, Kimberly Thomsen, lichengbiao29485, liushuo39497, liwenjie5993, liyao123321, lliulili, lujiazhen92883, luotong55295, luoyibing1593, luxingyu668, lvanqinglv98011, mary obrien, mengenci40549, nanshengjun07, niuzhi67664, parvovirus, piccirillonicholas, Pilsureic Fume, pskjgfsdufy, qiuchao97444, Richardyy, Ruth Hunter, Sandra Laporte, sdhiefytdiustf, Sean J Mejia, shanxinting, Sheryltt, TANGSHUNAGJJ, Thomas Duff, Thomassmgl, udsuhgsuytfu, wangchangqing454865, wangmengying51265, wangshijie18519, wanyuanhang14420, Warren Goodrich, wufush, wuxingchi15114, xiaguoqiang01020, xuaimin Store, xuhongzhe27933, yanpuxi, yanxuepeng54544, yongyanmei48084, yueshuai59147, yujunke24033, zhangjinpeng3675, zhanglijia1213, zhangruilan568, zhangyumeng14505 and Zzmonsa added to case caption.

NOTICE of Voluntary Dismissal by Royer Brands International S.A.R.L. as to certain defendants

NOTICE of Voluntary Dismissal by Royer Brands International S.A.R.L. as to a certain Defendant

MOTION by Plaintiff Royer Brands International S.A.R.L. for entry of default, MOTION by Plaintiff Royer Brands International S.A.R.L. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Royer Brands International S.A.R.L. in support of motion for entry of default, motion for default judgment[38]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[39]

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment 38 will be heard at the telephonic hearing set for 12/1/2022 at 10:30 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Due to a change in the Court's trial schedule, the telephonic status and motion hearing set for 12/1/2022 is stricken and reset for 12/7/2022 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. 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. Mailed notice

ATTORNEY Appearance for Plaintiff Royer Brands International S.A.R.L. by Jake Michael Christensen

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 38 is granted. The Court enters default against Defendants identified in Schedule A in accordance with FRCP 55(a). The ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to Plaintiff or their counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or their counsel. Enter final judgment order by default. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 12/7/2022. Mailed notice

NOTICE of withdrawal of bond [27] by John Summerfield. (Received for docketing 02/17/2023)

FULL SATISFACTION of Judgment regarding order 45 in the amount of $500,000 as to certain defendants