2022-cv-05936

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 402, receipt number AILNDC-19988144.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Schedule A regarding complaint[1]

MOTION by Plaintiff Dyson Technology Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dyson Technology Limited

Notice of Claims Involving Trademarks by Dyson Technology Limited

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Lawrence J. Crain

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Jake Michael Christensen

MAILED Trademark report to Patent Trademark Office, Alexandria VA

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 to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by January 17, 2023. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

MOTION by Plaintiff Dyson Technology Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Dyson Technology Limited 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 Giles Samuel Lane regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 4 - Parts 1-6 regarding declaration 16

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

(Exhibit 4-6)

MOTION by Plaintiff Dyson Technology Limitedfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Dyson Technology Limited in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

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.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. 3) is hereby granted. Plaintiff's motion for electronic service of process (Dckt. No. 18) is hereby granted. Plaintiff's motion for a temporary restraining order (Dckt. No. 13) is granted in part as stated in the accompanying order. Temporary Restraining Order to follow. For now, the Court is granting an asset freeze. But this Court is inclined to lift the asset freeze at a later time unless Plaintiff later seeks equitable monetary relief (like an accounting of profits) or unless Plaintiff can point this Court to a statute that expressly authorizes an asset freeze in connection with statutory damages. Plaintiff must promptly effectuate service of process. Plaintiff's counsel should not take it as a given that the Court will extend the TRO. Any motion for an extension for a TRO must establish a genuine need to do so, and must demonstrate diligence in response to the TRO. Mailed notice

SEALED TEMPORARY Restraining Order Signed by the Honorable Steven C. Seeger on 1/10/2023. Mailed notice.

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 $ 134,000.00 posted by Dyson Technology Limited. (Document not scanned)

MOTION by Plaintiff Dyson Technology Limited for extension of time of Temporary Restraining Order

DECLARATION of Jake M. Christensen regarding extension of time 25

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants

(Exhibit A)

DECLARATION of Jake M. Christensen regarding motion for preliminary injunction 28

(Exhibit 1)

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/24/2023, answer due 2/14/2023.

Declaration of Andrew D. Burnham

(Exhibit A)

MINUTE entry before the Honorable Steven C. Seeger: The initial status report deadline is extended to March 3, 2023. Mailed notice

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/6/2023, answer due 2/27/2023.

Declaration of Andrew D. Burnham

(Exhibit A)

MINUTE entry before the Honorable Steven C. Seeger: The initial status report deadline is extended to May 26, 2023.Mailed notice

MOTION by Plaintiff Dyson Technology Limited for entry of default, MOTION by Plaintiff Dyson Technology Limited for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for entry of default, motion for default judgment 34

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 35

(Exhibit 1)

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff Dyson Technology's motion for entry of default and default judgment (Dckt. No. 34) is hereby granted in part as follows. Plaintiff effectuated service of process on January 24, 2023. (Dckt. No. 30) The remaining defendants have not responded to the complaint. The responses to the complaint are long overdue. The Court hereby enters default under Rule 55(a) against all remaining defendants. The response to the motion for default judgment is due by May 12, 2023. No extensions. Defendants must file a motion if they seek a hearing. Plaintiff must serve a copy of this Order and file a certificate of service on the docket. Plaintiff must ensure that it has sent an up-to-date draft judgment with an up-to-date Schedule A in Word to the proposed order inbox. Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: Last year, this Court directed Plaintiffs' counsel to prepare, file, and email an Excel spreadsheet of all Schedule A cases that Plaintiffs' counsel had filed in this district in 2020 and 2021. The Court directs Plaintiffs' counsel to prepare, file, and email an updated version of the spreadsheet by May 19, 2023. The spreadsheet must include columns showing the case number, the case name, the date of filing each case, and the assigned judge. Counsel must file the spreadsheet on the docket, and must email an Excel version to the proposed order inbox: proposed_order_seeger@ilnd.uscourts.gov. The cover page of the filing must reveal how many Schedule A cases Plaintiffs' counsel filed in this district in 2022, and from 2020 to 2022. Mailed notice

CERTIFICATE of Service by Plaintiff Dyson Technology Limited regarding text entry, 38

(Exhibit A)

STATEMENT by Dyson Technology Limited pursuant to 39

(Exhibit 1)

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint initial status report is extended to July 24, 2023. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint initial status report is extended to August 24, 2023. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for an extension of the TRO (Dckt. No. 25) is hereby denied as moot. Plaintiff's motion for preliminary injunction (Dckt. No. 28) is hereby granted in part. Preliminary Injunction Order to follow. Plaintiff's motion for the entry of default (Dckt. No. 34) is hereby granted. The responses to the complaint are long since overdue. The Court hereby enters default against all remaining Defendants under Rule 55(a). A motion for default judgment is due by August 21, 2023. A response is due by August 28, 2023. Defendants must file a motion if they seek a hearing. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 8/14/2023. Mailed notice.

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MOTION by Plaintiff Dyson Technology Limited for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for default judgment 46

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 47

(Exhibit 1)

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint initial status report is extended to October 31, 2023.Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for default judgment (Dckt. Nos. 34, 46) is hereby granted. The responses to the complaint are long overdue. On August 14, 2023, this Court entered default against the Defendants under Rule 55(a). Final Judgment Order to follow. Permanent Injunction Order to follow. The complaint is dismissed. The case is closed. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Steven C. Seeger on 8/29/2023. Mailed notice.

PERMANENT INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 8/29/2023. Mailed notice.

NOTICE of appeal by Dyson Technology Limited regarding orders 51 Filing fee $ 505, receipt number AILNDC-21162058. Receipt number: n

EXHIBIT by Plaintiff Dyson Technology Limited Exhibit A regarding notice of appeal 53

DOCKETING Statement by Dyson Technology Limited regarding notice of appeal 53

NOTICE of Appeal Due letter sent to counsel of record regarding notice of appeal 53

TRANSMITTED to the 7th Circuit the short record on notice of appeal 53. Notified counsel.

ACKNOWLEDGMENT of receipt of short record on appeal regarding notice of appeal 53 ; USCA Case No. 23-2948.

CERTIFIED COPY OF OPINION from the USCA for the 7th Circuit; Argued 5/23/2024; Decided 3/24/2025 in USCA case no. 23-2948: We reverse and remand for further proceedings consistent with this opinion.

CERTIFIED COPY OF USCA JUDGMENT dated 3/24/2025 regarding notice of appeal 53 ; USCA No. 23-2948: We REVERSE, with costs and REMAND for further proceedings consistent with the opinion, in accordance with the decision of this court entered on this date.

MANDATE of USCA dated 4/15/2025 regarding notice of appeal 53 ; USCA No.23-2948; No record to be returned.

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin Tyler Joseph

MOTION by Plaintiff Dyson Technology Limited to Modify the Final Judgment Order

(Exhibit A)