2022-cv-04941

COMPLAINT filed by Jonas Sebastian Jodicke; Filing fee $ 402, receipt number AILNDC-19833588.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SCHEDULE A to complaint by Plaintiff Jonas Sebastian Jodicke Schedule A to Complaint (1) Modified on 1/20/2023.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Yanling Jiang

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Yi Bu

ATTORNEY Appearance for Plaintiff Jonas Sebastian Jodicke by Adam Grodman

CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (jk2,)

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,)

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file under seal

MOTION by Plaintiff Jonas Sebastian Jodicke for leave to file excess pages

MEMORANDUM in support of 10 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Jonas Sebastian Jodicke

(Exhibit 1, of Jonas Sebastian Jodicke's declaration)

EXHIBIT 2 by Plaintiff Jonas Sebastian Jodicke to the declaration of Jonas Sebastian Jodicke in support of memorandum in support of Plaintiff's EX PARTE motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by e-mail and/or electronic publication Modified on 1/20/2023.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

Exhibit 2-8

Exhibit 2-9

Exhibit 2-10

(Exhibit 2-11)

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for leave to file under seal 8, motion for leave to file excess pages 9, and ex parte motion for a temporary restraining order and other relief 10 are granted in part. Plaintiff's submissions establish that, were Defendants to learn of these proceedings before the execution of Plaintiff's requested preliminary injunctive relief, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, Plaintiff may for now file under seal the documents identified in the motion to seal and appearing at docket entries 2, 10, and 12. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, Plaintiff's filings support proceeding (for the time being) on an ex parte basis under FRCP 65(b)(1). Specifically, and as noted above, 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 equitable accounting. In addition, the Court finds, at least for now on this limited and one-sided record and without prejudice to revisiting the issue, that it has personal jurisdiction over the Defendants because they directly target their business activities toward consumers in the United States, including Illinois. Specifically, Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars, and have sold products using infringing and counterfeit versions of Plaintiff's trademarks to residents of Illinois. The evidence presented to the Court also shows that Plaintiff has demonstrated a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest, and there is no countervailing harm to defendants from an order directing them to stop infringement. 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 this Court and others have noted, there may be reason to question both the propriety of the joinder of all Defendants in this one action and whether plaintiff will pursue an accounting (which Plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the court is persuaded that 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 reconsider the asset freeze and joinder. Enter Sealed Temporary Restraining Order. Mailed notice

TEMPORARY RESTRAINING ORDER. Signed by the Honorable John F. Kness on 11/28/2022. Modified on 1/20/2023.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 10,000 posted by Jonas Sebastian Jodicke.

MOTION by Plaintiff Jonas Sebastian Jodicke for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable John F. Kness: Plaintiff's Motion to extend Temporary Restraining Order 17 is granted. Enter separate order. Mailed notice

ORDER ON MOTION FOR EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 12/12/2022. Mailed notice

MOTION by Plaintiff Jonas Sebastian Jodicke for preliminary injunction

MEMORANDUM by Jonas Sebastian Jodicke in support of motion for preliminary injunction 20

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

SUMMONS Returned Executed by Jonas Sebastian Jodicke as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/14/2022, answer due 1/4/2023.

(Declaration of Service)

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion 20 for entry of a preliminary injunction. In connection with that motion, which is entered and continued, Plaintiff must forthwith serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects on or before 12/29/2022." Plaintiff must file proof of service of the Court's statement within two business days of service. For the reasons stated in the Court's orders entering and extending the temporary restraining order ("TRO"), as well as in Plaintiff's earlier motion 17 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. Mailed notice

CERTIFICATE of Service by Plaintiff Jonas Sebastian Jodicke regarding terminate deadlines and hearings, set motion and R&R deadlines/hearings, 23

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for a preliminary injunction 20 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 22 24 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any Defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable John F. Kness on 1/17/2023. Mailed notice

NEW PARTIES: xlinart, Taphome, YuanRun, meiaibianlidian, Boyouth, WCHUANG, Beach Surfers, QuanCheng, iTapestry, Chifave, YSDGG Direct, baofengxianlixiangwangluokejijingyingbu, youdepot, Luoyang Boqi Trading Company, LoiFa, GuangRen, Hexixi01, Custom Luxury Textiles, FOURfool, ByHH, xihuaxianchiyingxianglongyalihezuoting, Jack West, leezeshaw, qingbaijiangquxiamuqidianjiancaijingyingbu, DING-FU, GENGJIANUO SHOP123, Sheehow, Similane, mnishengxin, Guy Morant, zhemingmaoyi, ResKorMiD, hejinshijubinshangmaoyouxiangongsi, LKCFNFURS, XunTu, Hajizdtkv-Store, Jekeno, Helen Mackey, goode store, Fashionable Boys and Girls, US Throws Blankets Store, Emmaan US, WanChanroot, hbfdgdsad, danzhoudanabufanshangmaoshanghang and Qingzhoushifusileishangmaoyouxiangongsi added to case caption.

NEW PARTIES: ' added to case caption.

NEW PARTIES: ' added to case caption.

NEW PARTIES: ZhuXinlong Store, ANHOPE, Kerry Page, XVWJ, AmzPainter, zanlin, xiaodongfushi, JIJIWANG, Slenyu, PURY, LIUGANGOO, CHENJINSTORE, Xiangchengshiaolafushangmaoyouxiangongsi, erosebridal, zhaixiaojian, YOUQUER, yiyujuhi, Felu, Kingko-Tee, Kathonex, customjoy, Personalizationcity, Howilath-US and SAASOLI added to case caption.

NEW PARTIES: Prosperity-US, Amiturgiore, qilar26, Wongs bedding USA(Gift shop) and maiquanqiu added to case caption.

NEW PARTIES: Prosperity-US, Amiturgiore, qilar26, Wongs bedding USA(Gift shop) and maiquanqiu added to case caption.

NEW PARTIES: boboCO, Kiraramall, sunmo, LJWrings, Li Yi Trade, Kaer decor, BIBONG STORE, Gold Stone Art Poster, Zkkhh, Smartworld Store, shengshunxingbaihuo, sanjiayi, laichaoriyongbaihuodian, HZWLSHUN shop, huangchunyu11, HJL Art, baofengxiankunruwangluokejijingyingbu, junyishuhua, Qingzhoushishuhuaishangmaoyouxiangongsi, Gludear, Vioflow, Coolsshop, Ainuno, N.G., BigCute, ENLACHIC, sjkdhs34, HANG NGUYEN THI THUU, J ROUND, gk8bkqwo, chengheshangmao1, Gopaka, sxiangart, HaniLav, TAKUSHI HF, KIDVOVOU, BarbedRose, KOBENEY, zhengdingxianmaxiangfuzhuangdian, zonXzon, liuhuandian, linzhenmeizhuangshicailiaoshanghang, CCHKanJun, NAYINLAN, ZZKKO, B.Baymax, Bunnistore, QoGoer Global, Sucor-us, Catamaran, Azuki-Fashion, Genuxury, JSJCHENG, NP Gifts For You, LINQIE Curtains Store, Hundred Demon Shop, FEASRT, Josid, Qingzhoushizaixijieshangmaoyouxiangongsi, UUUUAAA, Tianhe District Lianli, Vnmeans, HEFERI, BQKLOO, kuaikuaiot and Comforbed added to case caption.

NEW PARTIES: Ophelia Art, UJHAKSL, qfeiart, MMstyle, lgogvi, Yasala, AMmao, Yangyatian, Sweet Jane Inc, YBMABY store, XIAOCIGONGSI, Qingzhoushibadeshangmaoyouxiangongsi, MENGGE WALLPAPER, Qingzhoushiruizishangmaoyouxiangongsi, HETI-GUS, Khuqubeis, WFLNAQUAN, lianghuangshangdian, Smal Lucky, Aflyko, Oyisca, LONTA, LanZhenMao, aliceyang001, YiHangFuShiNA, jiang su kai pu dian qi, LIXIAW, ZHUhuidianpuq, Menghao shi, Shangshuixianrannianshangmaoyouxiangongsi, zhysylbaihuodian, SJXF Company, Miss Deng's shop, YH ArtTalk, Home garden suply, WangJianCong, RTSUSK, henanchenghuiwenhuachuanboyouxiangongsi, XIAOQINGT, SQmengke, gengshoutao223, Tsopk strore, YUEYI-SHOP, tiancaidamaijia, xianyouxianlvzenanshuiguojingyingbu, chenyu shop and zhengfuzhu1 added to case caption.

NEW PARTIES: DIYAGO(''7-21days Delivery) added to case caption.

(Bu, Yi) (Entered: 01/20/2023)

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MOTION by Plaintiff Jonas Sebastian Jodicke for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Jonas Sebastian Jodicke in support of motion for default judgment 31

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion 31 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 2/9/2023. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice

CERTIFICATE of Service by Plaintiff Jonas Sebastian Jodicke regarding terminate deadlines and hearings, terminate motion and R&R deadlines/hearings, set deadlines, 33

ATTORNEY Appearance for Defendant Jekeno by Ruoting Men

ATTORNEY Appearance for Defendant Jekeno by Tianyu Ju

MOTION by Defendant Jekeno for extension of time to file answer regarding complaint[1]

MOTION by Defendant Jekeno to withdraw motion for extension of time to file answer[37]

MINUTE entry before the Honorable John F. Kness: The motion [38] of Defendant Jekeno (Def. 39) to withdraw an earlier motion [37] for an extension is granted. The motion [37] for an extension is dismissed as moot. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 39 Jekeno

ORDER signed by the Honorable John F. Kness on 2/13/2023: Plaintiff's motion for entry of default judgment [31] is granted. Enter Final Judgment Order. The ten-thousand-dollar ($10,000) surety bond posted by Jonas Sebastian Jdicke is hereby released to Jonas Sebastian Jdicke or its counsel, Keith A. Vogt of Keith Vogt, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Keith A. Vogt of Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W Chicago, Illinois 60604 via certified mail. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER signed by the Honorable John F. Kness on 2/13/2023. Mailed notice

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Jonas Sebastian Jodicke to Plaintiff's Counsel Keith Vogt, Ltd. 33 West Jackson Boulevard, #2W Chicago, Illinois 60604 via certified mail #7019 2280 0000 0963 1941.

RETURN of U.S. Post Office Receipt, article no. 7019 2280 0000 0963 1941 executed on 02/21/2023.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 78 qilar26

SATISFACTION of Judgment as to Defendant no. 150 Comforbed

SATISFACTION of Judgment as to Defendant no. 51 ZhuXinlong Store