2022-cv-05575

COMPLAINT filed by Liforme Ltd.; Filing fee $ 402, receipt number AILNDC-19932265.

Exhibit Ex. 1 - Liforme Copyright Registration

Exhibit Ex.2 - Liforme Patent Registrations

(Supplement Provisionally Filed Under Seal - Schedule A Slip sheet)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Liforme Ltd. by David Edward Hutchinson

SEALED DOCUMENT by Plaintiff Liforme Ltd. Schedule A to Complaint

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Liforme Ltd.

CLAIM by Liforme Ltd. regarding Copyright.

(Supplement Schedule A to Copyright Claims AO 121 form)

MOTION by Plaintiff Liforme Ltd. for leave to file excess pages Motion to Exceed Page Limitation

Supplement Memorandum of Law in Support of Plaintiff's Ex Parte Application for Entry of a TRO, including a Temporary Transfer of control over the Defendant Internet Stores, a Temporary Asset Restraint, An Order for Expedited Discovery, and Granting Permission to Effectuate Service of Process by E-mail and Electronic Publication

Declaration Attorney Declaration (David E. Hutchinson) ISO TRO

Exhibit Ex. 1 to Attorney Declaration

Exhibit Ex. 2 to Attorney Declaration

Exhibit Ex. 3 to Attorney Declaration

Exhibit Ex. 4 to Attorney Declaration

Exhibit Ex 5 to Attorney Declaration

Exhibit Ex. 6 to Attorney Declaration

Declaration Declaration of James Armitage (Client)

Exhibit Ex. 1 to James Armitage Declaration (Copyright Registrations)

(Exhibit Ex. 2 to James Armitage Declaration (Patent Registrations))

SEALED DOCUMENT by Plaintiff Liforme Ltd. Ex 3 (Parts 1-16 of 16) of James Armitage Declaration

Exhibit Ex. 3 (2 of 16) of James Armitage Declaration

Exhibit Ex. 3 (3 of 16) of James Armitage Declaration

Exhibit Ex. 3 (4 of 16) of James Armitage Declaration

Exhibit Ex. 3 (5 of 16) of James Armitage Declaration

Exhibit Ex. 3 (6 of 16) of James Armitage Declaration

Exhibit Ex. 3 (7 of 16) of James Armitage Declaration

Exhibit Ex. 3 (8 of 16) of James Armitage Declaration

Exhibit Ex. 3 (9 of 16) of James Armitage Declaration

Exhibit Ex. 3 (10 of 16) of James Armitage Declaration

Exhibit Ex. 3 (11 of 16) of James Armitage Declaration

Exhibit Ex. 3 (12 of 16) of James Armitage Declaration

Exhibit Ex. 3 (13 of 16) of James Armitage Declaration

Exhibit Ex. 3 (14 of 16) of James Armitage Declaration

Exhibit Ex. 3 (15 of 16) of James Armitage Declaration

(Exhibit Ex. 3 (16 of 16) of James Armitage Declaration)

ATTORNEY Appearance for Plaintiff Liforme Ltd. by Christopher M. Tom

CLAIM by Liforme Ltd. regarding Patents.

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment. (jk2,) (Text entry; no document attached.)

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 copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Martha M. Pacold: For the reasons set forth in plaintiff's motions, the supporting memoranda, and the temporary restraining order, plaintiff's motions for leave to file under seal 7, for electronic service of process and for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 8 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 (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 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. Plaintiff's motion for leave to file excess pages 9 is also granted.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Martha M. Pacold on 10/14/2022:

Registry Deposit Information Form by Liforme Ltd. $10,000 Deposit.

BOND in the amount of $ 10,000.00 company check, Receipt no. 4624278008, posted by Liforme Ltd. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Liforme Ltd. of Defendant No. 146 (Jupiter Gear, Inc.)

MINUTE entry before the Honorable Martha M. Pacold: The court has received plaintiff's notice of dismissal 17, which seeks to voluntarily dismiss defendant No. 146 Jupiter Gear, Inc. under Rule 41(a)(1). Rule 41(a) is not the proper vehicle for dismissing some, but not all, parties to an action. Taylor v. Brown, 787 F.3d 851, 857 (7th Cir. 2015) ("Rule 41(a) should be limited to dismissal of an entire action.'). The court therefore construes plaintiff's notice of voluntary dismissal as a request for leave to amend the pleadings under Rule 15(a)(2) by dropping defendant No. 146 Jupiter Gear, Inc. from the Schedule A form, see Taylor, 787 F.3d at 857-58, and the court grants plaintiff leave to amend the pleadings. Plaintiff is directed to file an amended Schedule A form by 10/28/2022 identifying the remaining defendants. Jupiter Gear, Inc. terminated.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's ex parte motion to extend the TRO 19 is granted. Under Rule 65(b)(2), the court finds good cause to extend the TRO for 7 days to prevent defendants from transferring assets from their U.S. based financial accounts, modifying the names of their internet stores, or removing their internet stores from their current platforms. The court's TRO 14 entered on 10/14/2022 is extended until 11/4/2022 with respect to all Defendants identified in Schedule A to the Complaint except for Defendant 51, FootWorld, Defendant 68, Plyopic USA, Defendant 114, footworlduk, and Defendant 146, Jupiter Gear, Inc.

NOTICE by Liforme Ltd. re add and terminate parties, 18 Plaintiff's Notice of Filing First Amended Schedule A.

(Supplement Provisionally Filed Under Seal - First Amended Schedule A slipsheet)

SEALED DOCUMENT by Plaintiff Liforme Ltd. First Amended Schedule A.

ATTORNEY Appearance for Defendant Heathyoga by Jiyuan Zhang

ORDER Signed by the Honorable Martha M. Pacold on 11/4/2022: Plaintiff's second ex parte motion to extend temporary restraining order 24 is granted.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint (Text entry; no document attached.)

STIPULATION regarding asset restraint for Defendant Ewdoos.

STIPULATION regarding asset restraint for Defendant Heathyoga.

MOTION by Plaintiff Liforme Ltd. for preliminary injunction and to extend the temporary restraining order.

Supplement Memo in support of Motion for Preliminary Injunction

(Declaration Declaration of David E. Hutchinson)

SUMMONS Returned Executed by Liforme Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint on 11/10/2022, answer due 12/1/2022.

ATTORNEY Appearance for Defendant Ewedoos by Timothy Tiewei Wang

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 11/28/2022. Plaintiff shall serve defendants with this notice. For the reasons stated in the Court's orders entering and extending the TRO, as well as in Plaintiff's earlier motions 19, 24 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.

ATTORNEY Appearance for Defendant Quanzhoushi wanxiangxinxikejiyouxiangongsi d/b/a FASCINATING DEAL by Daniel I. Konieczny

MOTION by Defendant Quanzhoushi wanxiangxinxikejiyouxiangongsi d/b/a FASCINATING DEAL for extension of time to file response/reply as to motion for preliminary injunction, [28] Unopposed Motion for Extension of Deadline for Fascinating Deal to Respond to Plaintiff's Motion for Preliminary Injunction

MINUTE entry before the Honorable Martha M. Pacold: Defendant Quanzhoushi wanxiangxinxikejiyouxiangongsi d/b/a FASCINATING DEAL's unopposed motion for extension of deadline to respond to plaintiff's motion for preliminary injunction 33 is granted. Defendant Fascinating Deal is given until 12/5/2022 to respond to plaintiff's motion for preliminary injunction 28.

ANSWER to Complaint by Jamie Sevenoaks on behalf of https://www.ebay.com /usr/invisation. (Attachments)

MINUTE entry before the Honorable Martha M. Pacold: Defendant 117 (invisation) has filed an answer. [35]. By 12/13/2022, plaintiff and defendant invisation should file a joint status report proposing next steps in the litigation, including if necessary, a proposed discovery schedule. If the case proceeds to discovery, the court will likely refer the case to the assigned Magistrate Judge for supervision of discovery and settlement.

ATTORNEY Appearance for Defendant WannaToo by Zheng Gong

MOTION by Defendant Ewedoos for extension of time to file answer regarding complaint, 1

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Second Amended Schedule A to the Complaint Instanter.

STIPULATION regarding asset restraint for Defendant Fascinating Deal.

MOTION by Defendant WannaToo for extension of time to file answer regarding complaint, [1] Unopposed

MINUTE entry before the Honorable Martha M. Pacold: Defendant Ewedoos's unopposed motion for an extension of time to answer or otherwise plead to the complaint 38 is granted. Ewedoos to answer or otherwise plead to the complaint by 12/15/2022.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to file an amended Schedule A 39 is granted. The court finds that justice requires granting leave under Rule 15(a)(2). No. 47 Elon's Shop, No. 117 invisation, No. 128 Aegean Flagship Store, No. 129 Boji Flagship Store, No. 130 Huateng Yegang Flagship Store, No. 131 Hukai Sports Outdoor Store, No. 132 Kazixi Sports Outdoor Flagship Store, No. 133 Yan Wenming Outdoor Store, and No. 134 Zhenshike Flagship Store terminated. Plaintiff has already filed an amended Schedule A on the docket 40 identifying the remaining defendants.

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed the Stipulation regarding asset restraint for defendant Fascinating Deal 41. The Stipulation 41 is granted.

MINUTE entry before the Honorable Martha M. Pacold: Defendant WannaToo's unopposed motion for extension of time to answer or otherwise plead 42 is granted. Defendant WannaToo to answer or otherwise plead to the complaint by 1/31/2023.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Third Amended Schedule A to the Complaint Instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend the pleadings under Rule 15(a)(2) 47 is granted. The court finds that justice requires granting leave. Plaintiff has filed an amended Schedule A on the docket 48. Defendants No. 42 DevonloskyDirect, No. 52, Global Diffusion Limited, No. 62 KUYOU Outdoor, and No. 73 WOWELL DIRECT terminated.

STATUS Report Plaintiff's Status Report Regarding Defendant Invisation by Liforme Ltd.

MINUTE entry before the Honorable Martha M. Pacold: Recognizing that Defendant No. 117 invisation was dismissed 44, the court relieves Plaintiff of its obligation to file the joint status report ordered in 36.

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

MINUTE entry before the Honorable Martha M. Pacold: Defendant Ewedoos's unopposed motion for an extension of time to answer or otherwise plead 52 is granted. Defendant Ewedoos to answer or otherwise plead by 1/3/2023.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Fourth Amended Schedule A to the Complaint Instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping Defendants No. 57 Heathyoga, No. 75 YOBU DEZIGNS, No. 122 online.store, and No. 143 Techonline 54 is granted. The court finds that justice requires leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 55. Defendants No. 57 Heathyoga, No. 75 YOBU DEZIGNS, No. 122 online.store, and No. 143 Techonline terminated.

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.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Fifth Amended Schedule A to the Complaint instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A to the complaint 58 is granted. Plaintiff has already filed an amended Schedule A on the docket 59. Defendants Hysenm US, Laras Store, and WannaToo terminated.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Sixth Amended Schedule A to the Complaint Instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping Defendant No. 76 YYUSFY 61 is granted. The court finds that justice requires leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 62. Defendant No. 76 YYUSFY terminated.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Seventh Amended Schedule A to the complaint instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping defendants No. 42 BeautyHomeLifeEasy; No. 43 CHENGxuan; No. 48 Ewedoos; No. 50 Fascinating Deal; and No. 74 XSDbeimei 64 is granted. The court finds that justice requires leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 65. Defendants No. 42 BeautyHomeLifeEasy; No. 43 CHENGxuan; No. 48 Ewedoos; No. 50 Fascinating Deal; and No. 74 XSDbeimei terminated.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Eighth Amended Schedule A to the Complaint Instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping defendants No. 9 Nanjing Huaimao Sporting Goods Co., Ltd.; No. 10 Ningbo Pidegree Rubber And Plastic Industry Co., Ltd.; No. 12 Wuhan FDM Eco-Friendly Material Co., Ltd.; No. 41 August Grocery Store; and No. 61 Kaneco 67 is granted. The court finds that justice requires granting leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 68. Defendants No. 9 Nanjing Huaimao Sporting Goods Co., Ltd.; No. 10 Ningbo Pidegree Rubber And Plastic Industry Co., Ltd.; No. 12 Wuhan FDM Eco-Friendly Material Co., Ltd.; No. 41 August Grocery Store; and No. 61 Kaneco terminated.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff is directed to file a status report by 3/28/2023 as to the status of the motion for a preliminary injunction 28 and whether it is currently opposed, if so, by whom it is opposed, and the status of briefing on the motion.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Ninth Amended Schedule A to the Complaint Instanter.

STATUS Report Plaintiff's Status Report Regarding Motion for Preliminary Injunction. by Liforme Ltd.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping defendants No. 16 7 Stars Energetic Sporting & Entertainment Store; No. 110 calisthenics; and No. 137 Pharamond Life 71 is granted. The court finds that justice requires granting leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 72. Defendants No. 16 7 Stars Energetic Sporting & Entertainment Store; No. 110 calisthenics; and No. 137 Pharamond Life terminated.

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed plaintiff's status report 73. Plaintiff is directed to submit a revised proposed preliminary injunction order and a track changes copy to Proposed_Order_Pacold@ilnd.uscourts.gov. The motion for preliminary injunction 28 remains under advisement.

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 Exhibit 1 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 4/12/2023:

ORDER: The Clerk of Court is directed to unseal any previously sealed documents in this matter. Signed by the Honorable Martha M. Pacold on 4/12/2023. Mailed notice.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED 10th Amended Schedule A to the Complaint Instanter.

NEW PARTIES: Anhui Sky Color Rubber Co., Ltd. (1), CHANGZHOU ENGINE RUBBER&PLASTIC CO., LTD. (2), Dongguan Mika Technology Co., Ltd (3), Hangzhou Yufan Technology Co., Ltd. (4), Hefei Bstar Rubber Mats Co., Ltd. (5), Huangshi Tingbao Trading Co., Ltd. (6), Jiangsu Chaomanyi Sports Goods Co., Ltd. (7), Jinhua Moving Houseware Co., Ltd (8), Shenzhen Shanglimei Sports Technology Co., Ltd. (11), Zhejiang Hengwei Technology Co., Ltd. (13), 3366 Factory Factory Store (14), 48 hours delivery Store (15), Awesome Choices Store (17), Be-champion Store (18), Bstar Yogi Products Store (19), Chendq888 Store (20), FITYOU FITNESS&OUTDOOR Store (21), For your Store (22), Hanuman Store (23), IHOMEINF Official Store (24), KAPPQ Store (25), Lets Deemo Store (26), Panther Military Hunting Store (27), Penggue First Store (28), Sennuoye Trading Store (29), Senoya Sporting Store (30), Shanghai 4Season Outdoor Products Store (31), Shop912197075 Store (32), slochi01 Store (33), StartingYoga& Pilates Store (34), TAKE CARE Store (35), TAPA Yoga Products Store (36), Zhiyuan E-commerce Co., Ltd. Store (37), zhongzuishang Official Store (38), 4W YOGA (39), AIRMERRY ACTIVEWEAR (40), Citta Nomad (44), dongjiahong988 (46), Fanyangyang (49), Guanchuang (53), guojing666 (54), HangKeKeJi (55), hauphu-store (56), hukjieda (58), Inspire Nutrition UK (60), LUSHENA (64), MEWE (65), Mifly (66), Paidui (67), shanghaitongzhaoguojimaoyiyouxiangongsi (69), ShouGuangShiLiTaiNongYeKeJiYouXianGongSi (70), sunleihao (71), VELUCCHI (72), zhijianwork (77), ajpq (78), alvare1 (79), amam2020 (80), beer2 (81), bljs (82), bq9n (83), d27x (84), d8vk (85), dffrft (86), dmjq (87), dxpt (88), e1vg (89), frhd (90), h151 (91), j9aa (92), karh (93), ldqk (94), lmooj (95), lpdiy (96), lwkdo (97), mvrf (98), nhat (99), q9an (100), rhq1 (101), Saien_20211 (102), tpxt (103), ttre (104), vmsu (105), wkgn (106), x6l2 (107), bandaranaikeproducts_online (108), btoy_emarket (109), daga_business (111), dilshan_1448 (112), discover-bargains (113), futureworks_911 (115), hola_trades (116), james-warehouse (118), jb404 (119), ktsp7 (120), mrjohnw297 (121), rrsaleslimited (123), s4ndra (124), stikine-indianmart (125), udaralakruwan (126), variety-dealsstore (127), VOGROUND SPHY (135), Shenzhen Yangyu Trading Co., Ltd. (136), Guangzhoushihuangdoukuajingmaoyiyouxiangongsi (138), Haxercise (139), HONGRON (140), LOLIDO US (141), SHENZHENSHIBALIDIANZIKEJIYOUXIANGONGSI (142), WannaToo (144), Darren209 (145), lqgl lddk (147) and Richledge (148) added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping defendants No. 4 Hangzhou Yufan Technology Co., Ltd.; No. 5 Hefei Bstar Rubber Mats Co., Ltd.; No. 8 Jinhua Moving Houseware Co., Ltd; and No. 19 Bstar Yogi Products Store 79 is granted. The court finds that justice requires granting leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended schedule A on the docket 80. Defendants No. 4 Hangzhou Yufan Technology Co., Ltd.; No. 5 Hefei Bstar Rubber Mats Co.; No. 8 Jinhua Moving Houseware Co., Ltd; and No. 19 Bstar Yogi Products Store terminated.

MOTION by Plaintiff Liforme Ltd. for entry of default and default judgment.

Supplement Memo in support of Motion for Entry of Default and Default Judgment

Declaration Declaration of Christopher Tom in support of Motion for Entry of Default and Default Judgment

Exhibit Ex. A - service email (combined pictures)

Exhibit Ex. B - Site Down website

Exhibit Ex. C - Tenth Amended Schedule A

(Exhibit Iron Maiden and Zuru Default Judgments)

MINUTE entry before the Honorable Martha M. Pacold: The court takes plaintiff's motion for entry of default and default judgment 82 under advisement. Any defendant objecting to plaintiff's motion for entry of default and for default judgment 82 must enter an appearance and file a written objection by 6/1/2023. If no objections are filed, the court will consider the motion unopposed. Plaintiffs shall serve defendants with this notice.

AFFIDAVIT of Service filed by Plaintiff Liforme Ltd. regarding Plaintiff's Motion for Default and documents in support of the Motion for Default served on all remaining Defendants subject to Plaintiff's Motion for Default on May 20, 2023

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff is directed to send to the court's proposed order box by 12:00 p.m. on 6/6/2023 (a) a proposed default judgment order including (b) a track changes version, see the standing order on the website, and including (c) an updated Schedule A that clearly excludes all dismissed defendants.

MOTION by Plaintiff Liforme Ltd. to amend/correct Schedule A to the Complaint Instanter.

AMENDED Eleventh Amended Schedule A to the Complaint Instanter.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to amend Schedule A by dropping defendant No. 136 Shenzhen Yangyu Trading Co., Ltd. 86 is granted. The court finds that justice requires granting leave to amend under Rule 15(a)(2). Plaintiff has already filed an amended Schedule A on the docket 87. Defendant No. 136 Shenzhen Yangyu Trading Co., Ltd. terminated.

ORDER: In the court's 5/18/2023 minute entry, it gave all defendants until 6/1/2023 to object to plaintiff's motion for entry of default and default judgment 82. See 83. No defendant has objected. The court therefore grants plaintiff's motion for entry of default and default judgment 82. Based on the evidence submitted in support of the temporary restraining order and the motion for entry of default and default judgment, and the admission of liability by virtue of the default, plaintiff has established that the infringement was willful, that damages should be awarded in the amount specified in the order, and that a permanent injunction should be entered. Plaintiff has shown that the infringement of its copyright and patents causes it irreparable harm in the form of diminished goodwill and brand confidence, damage to plaintiff's reputation, loss of exclusivity, and loss of future sales; that monetary damages are inadequate to address these harms; and that the public interest would not be disserved by a permanent injunction. No defendants have appeared to argue otherwise; thus, the court also finds that the balance of the hardships favors a permanent injunction. 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 David Edward Hutchinson, 1136 S. Delano Court West, Ste B201, 2068, Chicago, IL 60605 via certified mail. Enter Default Final Judgment Order. Civil case terminated. Signed by the Honorable Martha M. Pacold on 6/7/2023. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Martha M. Pacold on 6/7/2023. Mailed notice

MOTION by Plaintiff Liforme Ltd. for leave to appear as Attorney by Blake Goebel

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for attorney appearance 91 is granted. Attorney Blake Goebel may enter an appearance on behalf of plaintiff.

ATTORNEY Appearance for Plaintiff Liforme Ltd. by Blake C Goebel

MOTION by Attorney David Hutchinson to withdraw as attorney for Liforme Ltd. No party information provided

MOTION by Attorney Christopher Tom to withdraw as attorney for Liforme Ltd. No party information provided

ORDER: Plaintiff's motion for withdrawal of attorney David E. Hutchinson as counsel of record 94 is granted. Plaintiff's motion for withdrawal of attorney Christopher Tom as counsel of record 95 is granted. Signed by the Honorable Martha M. Pacold on 7/11/2023. Mailed notice

ATTORNEY Appearance for Plaintiff Liforme Ltd. by Rossana Baeza

MOTION by Plaintiff Liforme Ltd. for disbursement of funds

DISBURSEMENT ORDER Signed by the Honorable Martha M. Pacold on 9/17/2025: Mailed notice