2022-cv-05611

COMPLAINT filed by Hallmark Licensing, LLC ; Filing fee $ 402, receipt number AILNDC-19940635.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Hallmark Licensing, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Hallmark Licensing, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hallmark Licensing, LLC

Notice of Claims Involving Trademarks by Hallmark Licensing, LLC

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC 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

MOTION by Plaintiff Hallmark Licensing, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Hallmark Licensing, LLC in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Al Mauro regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Hallmark Licensing, LLC Exhibit 2 - Parts 1 - 5 regarding declaration 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

(Exhibit 2-5)

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

MEMORANDUM by Hallmark Licensing, LLC in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [11] [16] are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. 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 is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/25/2022. Notices mailed.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ $50,000.00 posted by Hallmark Licensing, LLC

MOTION by Plaintiff Hallmark Licensing, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Hallmark Licensing, LLC in support of extension of time[21]

Declaration of Marcella D. Slay

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 21 is granted. The TRO is extended to 11/22/22. Notices mailed.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

MOTION by Plaintiff Hallmark Licensing, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Hallmark Licensing, LLC in support of motion for preliminary injunction[26]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Hallmark Licensing, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/17/2022, answer due 12/8/2022.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 11/21/22. If no objections are filed, the motion will be considered unopposed. Notices mailed.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

PRO SE Appearance by Unknown Liu Mengqi.

RESPONSE by Liu Mengqi to Plaintiff's motion for preliminary injunction order (Exhibits).

MINUTE entry before the Honorable Manish S. Shah: Defendant Zenginn filed a response to the motion for a preliminary in junction through its operator, an individual unrepresented by counsel. Entities may not appear in federal court without counsel. The response is not a proper response. No other defendants have appeared or objected to the motion for a preliminary injunction. Although the court has doubts about personal jurisdiction over defendants who did not actually ship product to Illinois, the absence of a proper objection and plaintiff's submissions to date establish that a preliminary injunction should issue. The reasons justifying the TRO continue to support a preliminary injunction. The motion [26] is granted. The court advises plaintiff to promptly evaluate the defendants and consider the statements attempted to be filed by Zenginn. 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 Schedule A 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. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/22/2022. Notices mailed.

NEW PARTIES: Hangzhou Gravity Industrial Co., Ltd., Yangzhou Home Ka Crafts Ltd., AW cos Store, Beata Store, Comfy Apparel Store, cooltee Store, Frigg Sweethome Store, Girl's Clothes Store, GOODLL Store, LOVELYFOX Official Store, LovePin3 Store, New Shape Store, Shop1100229685 Store, Shop5704132 Store, Shop910726068 Store, Shop911044031 Store, Shop911299019 Store, SJHKEEP2 Store, A1QTMHDEK3EPDK, A2L2FESFQHWJU9, A2Z5T637JH3MX8, A3FLXG2T4T2BXL, A3UTNWR1CM3PJA, AFS7ZM91D4DN1, Andrew Earchand, AOHVO9HTV2PX6, ArnoldoBlack, beijiaoshangmao, Blanket Decor Store, CEGEGVDWFECV, CEWQ, changshananguanmaoyiyouxiangongsi, CHENCHENLIUERDEDIANPU, Ciicnnesreh, CNlannuoshangmao, DARU HK TRADE CO LIMITED, eoeioa (7-15 Days Delivery), fan SE, feifeishipin, Fronage, GOBANNEY, gsdhgsrhrh, GuanLiBS, HANWU, HAPPY-ZHL, henanchuanyaowangluokejiyouxiangongsi, hexianyusix, Jiezhen7890, JOYFUL INTERNATIONAL TRADING HK LIMITED, JSY LLC, kajaka, KunMingFanYuZhenMingDianZiShangWuYouXianGongSi, linyijifuxinxijishufuwuyouxiangongsi, LONBANSTR, maiquanqiu, MarandaRivera, Mary Atiltner, nanninghuangchenmaoyiyouxiangongsi, Personalized design, profession Custom, PSADKID, putianshichengxiangqulumierongmaoyiyouxiangongsi, Q&L US, RGTDHDTYH, Richer-yuxin231, springshen, srhsh, Sunshuai, tianxiaofu, TRFDGJK, Viaecone Gift, XIAO NING YU, xinfushengxinlingshoushanghang, xin-yuan, xinyuwaye, xunchengmiaowangluokeji, Yeager Home, YESCUSTOM OFFICIAL, Yourtops, YUELIANG, ZXQ Wall Decor, Pillow6218, Beiwei, Benboy, Free Choice, Huahong, KZKRUS, longyanshijunruixinxijishuyouxiangongsi, Luxury Consuming, shengming, Shenzhen Dali Industry Co., Ltd., SHENZHENSHIRUNRONGWUJINYOUXIANGONGSI, Shunrunxiang, US DEALS, Wonderful buy, Zenginn, 2021 3D Print Factory, caozhongzhong573, Cpre de Douleur, Janette Moser, JDTJbxfngfxn, linmua, lisa letterman, Pisblocto Reffen, pspinosa93 and Xinyuyuan added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Berel Yonathan Lakovitsky

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to a Certain Defendant

MOTION by Plaintiff Hallmark Licensing, LLC for entry of default, MOTION by Plaintiff Hallmark Licensing, LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Hallmark Licensing, LLC in support of motion for entry of default, motion for default judgment 42

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 43

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment 42 before Honorable Manish S. Shah on 12/28/2022 at 09:45 AM.

ATTORNEY Appearance for Defendant KZKRUS by Ruoting Men

ATTORNEY Appearance for Defendant shengming by Adam Edward Urbanczyk

MOTION by Defendant shengming for extension of time UNOPPOSED

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [48] is granted. Defendant Shengming has until 1/17/23 to respond to the complaint. Any objections to the motion for default judgment must be properly fled by 9:30 a.m. (U.S. Central Standard Time), on 12/28/22. If no objections are filed the motion will be considered unopposed. No appearance on the motion is necessary. The motion is taken under advisement.

MOTION by Defendant KZKRUS for extension of time First Unopposed, Extend to Jan 10, 2023

MINUTE entry before the Honorable Manish S. Shah: Defendant KZKRUS's motion for extension of time [50] is granted. KZKRUS shall respond to the complaint by 1/10/23.

MINUTE entry before the Honorable Manish S. Shah: No objections to the motion for default judgment have been filed. The motion [42] is granted, as to all remaining defendants except KZKRUS and shengming. Enter Default Judgment. Plaintiff shall file a status report by 1/17/23 as to the remaining defendants. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/28/2022. Notices mailed.

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

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 Hallmark Licensing, LLC to approve consent judgment as to a Certain Defendant shengming

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion to approve consent judgment[56] before Honorable Manish S. Shah on 1/10/2023 at 09:45 AM.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 1/9/2023: The motion to approve consent judgment [56] is granted. No appearance on 1/10/23 is necessary. Notices mailed.

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

NOTICE of withdrawal of Bond [24] by Counsel/Designated person.

MOTION by Plaintiff Hallmark Licensing, LLC for entry of default, MOTION by Plaintiff Hallmark Licensing, LLC for default judgment as to Defendant KZKRUS

Exhibit A

MEMORANDUM by Hallmark Licensing, LLC in support of motion for entry of default, motion for default judgment[60]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[61]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment[60] before Honorable Manish S. Shah on 1/19/2023 at 09:45 AM.

STATUS Report per [52] by Hallmark Licensing, LLC

TRANSCRIPT OF PROCEEDINGS held on 01/19/2023 before the Honorable Manish S. Shah. Order Number: 45034. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 2/9/2023. Redacted Transcript Deadline set for 2/20/2023. Release of Transcript Restriction set for 4/19/2023.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment [60] is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 1/19/2023. Notices mailed.

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[53] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[53] as to certain defendant

FULL SATISFACTION of Judgment regarding order[67] in the amount of $100,000 as to certain defendant