2022-cv-06371

COMPLAINT filed by Motley Crue, Inc.; Filing fee $ 402, receipt number AILNDC-20046814.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Motley Crue, Inc. Schedule A to Complaint [1]

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Motley Crue, Inc.

ATTORNEY Appearance for Plaintiff Motley Crue, Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Motley Crue, Inc. by Yi Bu

ATTORNEY Appearance for Plaintiff Motley Crue, Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiff Motley Crue, Inc. by Yanling Jiang

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.

SEALED DOCUMENT by Plaintiff Motley Crue, Inc. [Amended] Schedule A[2] to Complaint[1]

MOTION by Plaintiff Motley Crue, Inc. for leave to file [Certain] Documents Under Seal

MOTION by Plaintiff Motley Crue, Inc. for leave to file excess pages

MEMORANDUM In Support of [12] Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-2, Declaration of Keith Vogt

Declaration of Thomas Schlegel

Exhibit 1, Declaration of Thomas Schlegel

SEALED EXHIBIT by Plaintiff Motley Crue, Inc. Sealed Exhibit 2, Declaration of Thomas Schlegel regarding memorandum in support of motion, [13]

CERTIFICATE of Service by Plaintiff Motley Crue, Inc. Ex Parte Motion[12] and Proposed Order

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a motion [12] for temporary restraining order. Plaintiff's motion is ex parte as to the defendants, but plaintiff has given notice of the motion [15] to the non-party providers of services to the defendants named in the proposed temporary restraining order (collectively "third-party providers"). The third-party providers have until noon on Tuesday, November 22, 2022, to object to plaintiff's request that the court find that it has personal jurisdiction over them and that they are in active concert or participation with the defendants named in schedule A to the complaint. See Fed. R. Civ. P. 65(d)(2). The third-party providers may file an objection in writing or request a hearing, to be conducted via teleconferencing, by sending a message to Chambers_Gottschall@ilnd.uscourts.gov, with a copy to all counsel of record, on or before noon on Tuesday, November 22, 2022. Plaintiff is ordered to serve the third-party providers with a copy of this order and file a certificate of service on or before November 18, 2022. Mailed notice

CERTIFICATE of Service by Plaintiff Motley Crue, Inc. regarding text entry, [18]

ATTORNEY Appearance for Objector ContextLogic, Inc. by Christine Elizabeth Skoczylas

OBJECTIONS of Non-Party ContextLogic, Inc.

MINUTE entry before the Honorable Joan B. Gottschall: Non-party ContextLogic Inc. ("ContextLogic"), filed an objection 21 to plaintiff's motion for a temporary restraining order in which it states, "Although ContextLogic is a non-party, it does not dispute or contest the Court's jurisdiction over it with respect to the enforcement of a temporary restraining order proposed by Plaintiff that may be entered in this case or any obligations that ContextLogic may have thereunder." ECF No. 21 at 2. ContextLogic further states that it "does not understand Plaintiff to be alleging that ContextLogic is acting in active concert or participation with the named defendants," but it "specifically objects" to any such finding by the court. Id. at 2-3. Based on ContextLogic's non-opposition to the requested relief, plaintiff's motion 12 for temporary restraining order is granted. The court makes no finding on whether ContextLogic is acting in active concert or participation with the named defendants. Also granted are plaintiff's motion 11 for leave to exceed the Local Rule 7.1 page limit and motion 10 for leave to file amended Schedule A to the complaint 9 and Exhibit 2 14 to the declaration of Thomas Schlegel under seal. Enter sealed temporary restraining order. A preliminary injunction hearing to be held by teleconference is tentatively set for December 7, 2022, at 10:30 a.m. Due to the COVID-19 pandemic and in accordance with the guidance of General Order No. 21-0027, the court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 2 to the declaration of Thomas Schlegel and any e-mail addresses provided for defendants by third parties that includes a link to said website. Any motion to extend the temporary restraining order is due on or before December 2, 2022. Mailed notice

SEALED Temporary Restraining Order. Signed by the Honorable Joan B. Gottschall on 11/23/2022. Mailed notice

SURETY BOND in the amount of $ 10,000 posted by Motley Crue, Inc. (Document not imaged)

MOTION by Plaintiff Motley Crue, Inc. for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable Joan B. Gottschall: The deadline to request a hearing has come and gone (see [22]), and no request for a hearing has been received. Plaintiff's motion [25] to extend the sealed temporary restraining order [23] to 10:30 a.m. on 12/21/2022 is granted. The preliminary injunction hearing tentatively set for 12/7/2022 is stricken and reset to 12/21/2022 at 10:30 a.m. Due to the ongoing COVID-19 pandemic and in accordance with General Order No. 21-0027, the court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 2 to the declaration of Thomas Schlegel and any e-mail addresses provided for defendants by third parties that includes a link to said website. Mailed notice

MOTION by Plaintiff Motley Crue, Inc. for preliminary injunction

MEMORANDUM by Motley Crue, Inc. in support of motion for preliminary injunction 27

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

Tentative NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 27 before Honorable Joan B. Gottschall on 12/21/2022 at 10:30 AM.

MOTION by Plaintiff Motley Crue, Inc.Plaintiff's Motion for Electronic Service Of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Motley Crue, Inc. in support of motion for miscellaneous relief 30

Declaration of Keith A. Vogt

(Exhibit 1-2, Declaration of Keith Vogt)

MINUTE entry before the Honorable Joan B. Gottschall: The court having received no request for a hearing by the deadline [26] of 12/19/2022, the preliminary injunction hearing set for 12/21/2022 is stricken. Plaintiff's motion for preliminary injunction [27] and motion for electronic service of process [30] are granted. Enter preliminary injunction order. In accordance with the order, the clerk is directed to unseal Amended Schedule A to the complaint [9], Exhibit 2 to the Declaration of Thomas Schlegel [14], and the temporary restraining order [23]. The law firms of Keith Vogt, Ltd., and JiangIP LLC are hereby ordered to add ALL defendant names listed in Amended Schedule A to the docket within three business days. Instructions can be found on the court's website located at www.ilnd.uscourts.gov/instructions. The next status report is due on or before 2/22/2023. Counsel for plaintiff is reminded that a prior iteration of Schedule A to the complaint [2] remains sealed. The good cause shown for sealing this document was limited to the time needed to freeze the defendants' assets. It is unclear why good cause continues to exist to protect the identity of defendants who have been dismissed. If plaintiff does not wish to have all presently sealed documents unsealed at the conclusion of this case, it must show good cause to continue to maintain the seal before this case is closed. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Joan B. Gottschall on 12/19/2022. Mailed notice

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

NEW PARTIES: AAdevincol, ariqiyan32447, bomrjyngon, Brocylon, Brother & Sister Shop, Chenlili789, Christophercb, daiwenjie41761, David Bonebreak, demgfjsnl, dongyimeng9995, dukun Store, Emersoncheu, fucailing55189, fuhan182, fumingyue43831, gaohui231, glazingmotphvro, gongni fashion, guoliujiang20136, haojianquan55206, Herbert Roach, huangyong93688, huanping15804, James Fitzpatrick, James Willcox, JamiePrimarHcG, jinxiao35879, Jonathan Thompson, Jose Hawkins, khft19842, Kilbazar, kongfanli48618, lichuang39796, licuicui5203, lidawen55888, lifengfe22805, lilianxi3572, linyu fashion, liruotong2042, LiuGuoqiang1988510, liuhaibin163, liujinyuan21395, liukaixin51062, liupenglong71665, liusanyuan1197, liuxishan22806, liwannan01561, liwenxang74380166 and lixin71217 added to case caption.

NEW PARTIES: liyapeng1234, lizixuan1394, luhnmmivs, Lujiup Store, luoqi4455, mahua Store, maolei4150, mcshoofegcitg, mengkecen70328, Michaeweekly, Mobility Stock Trading, nanding60483, niuzhi67664, pangmeili52607, peimengyue55108, puhaofei56950, qiuping65197, quyan08610, renqingmin51194, RicScore, ryan williamsu, Sarengaowa, shangzhenfei3826, sksdjfsdhj, stenedchcj, stores keila, sunboyu58228, sunling5455, tanjianing0542, teatearlsmr, uci292, unsqueezing, vyujkloi, wangchangqing01468, wangjiale555, wangshuang794684, wangxianghui39773, wangyingming6621, wangzezhong06926, weiqiumei226, wuming90212, wushuaihua05948, wuxingchi15114, xiaguoqiang01020, xiaxulan42671, xiayujia57514, Xiongxiang66058, xuyonghui53741, xuzhihong62097 and yangjinyou1017 added to case caption.

SUMMONS Returned Executed by Motley Crue, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/20/2022, answer due 1/10/2023.

(Declaration of Service)

NEW PARTIES: yangqing123, yanguofei49143, yangxuying3764, yanwenxue48580, Yinyijun423, yueshuai59147, yuwanting30727, Yydekzn, Yymarse, zhanghao15163, zhangjialiang76775, zhangnengyuan10950, zhangxiaoli11194, zhaojie76454, zhaoshi1234, zhengfhuai, zhengyuanxiang71068, zhongkaiqiang39593, zhouxiyu40247, zhuminggang17798, AIBULANTE, ANHDUNG9332, Anhthukutehp1, babymilo, Bamirachel shop, bang299popu, borubaihuo, chaochayouhua, chenbiaoshuiguoshanghang, chunlinwenjujiu11, dongguanxieduofuzhuangyouxianzerengongsi, foshanyujietingmaoyiyouxiangongsi, gfdfbfdwqfgregtbg, HaiKouShiXiangFeiShangMaoYouXianGongSi, haikoushiyingchengshangmaoyouxiangongsi, henghongwenjujingyingbu, HuaJu-SHOP, ingtanhongdahaiyunyouxiangongsi, JINFENGFANGFANG, JLKDSJFKDS, junfanwenjujingyingbu, KuangGeShop, Kuniwoo Store, KunMingWangJiShangMaoYouXianGongSi, licfjiedaolinchenwenjujingyingbu, linxinquanfuzhuangchang, lishengjiee, menglili, Ngoc tam, PRIME SHELF, RHRTHWRTHRTH, SIANSIYAMA SHUE1, Siping US, SongYuan Co, Taste Longjing tea, Tea painting, tea tea canvas poster, tjkethjewsrgsfr, TOnghfknb and VAN SON MAI added to case caption.

NEW PARTIES: VAN.NAMAxMAS2, WHDFODS2PKSJDKS, XA/MINQIONGSHOP, XA/SANYATIANSTORE, yiwanbommQ, YUANWEIMART, Yuruanmao-Co, Yuzhengliu, ZEXM0889, ZHONGSHENGMAMA and ZHUMUS added to case caption.

NEW PARTIES: ' added to case caption.

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 defendsant no. 169 zexmo889 and defendant no. 145 licfjiedaolinchenwenjujingyingbu

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a notice of voluntary dismissal 36 of its claims against defendant nos. 169 and 145 without prejudice. The notice of dismissal is ineffective under Seventh Circuit case law holding that the proper way to drop fewer than all claims or defendants is to amend the complaint. Taylor v. Brown, 787 F.3d 851, 857-58 (7th Cir. 2015) (citing Berthold Types Ltd. v. Adobe Sys. Inc., 242 F.3d 772, 777 (7th Cir. 2001) (other citation omitted)). The court construes plaintiff's notice of voluntary dismissal as a motion for leave to amend the complaint to drop the defendants named in its notice of voluntary dismissal and grants plaintiff's motion. See Fed. R. Civ. P. 15(a). Plaintiff's amended complaint is due on or before 1/10/2023. Mailed notice

NOTICE of Voluntary Dismissal by Motley Crue, Inc. as to [Certain] Defendant

AMENDED complaint by Motley Crue, Inc. against ', AAdevincol, AIBULANTE, ANHDUNG9332, Anhthukutehp1, Bamirachel shop, Brocylon, Brother & Sister Shop, Chenlili789, Christophercb, David Bonebreak, Emersoncheu, HaiKouShiXiangFeiShangMaoYouXianGongSi, Herbert Roach, HuaJu-SHOP, JINFENGFANGFANG, JLKDSJFKDS, James Fitzpatrick, James Willcox, JamiePrimarHcG, Jonathan Thompson, Jose Hawkins, Kilbazar, KuangGeShop, KunMingWangJiShangMaoYouXianGongSi, Kuniwoo Store, LiuGuoqiang1988510, Lujiup Store, Michaeweekly, Mobility Stock Trading, Ngoc tam, PRIME SHELF, RHRTHWRTHRTH, RicScore, SIANSIYAMA SHUE1, Sarengaowa, Siping US, SongYuan Co, TOnghfknb, Taste Longjing tea, Tea painting, The Partnerships and Unincorporated Associations Identified on Schedule A, VAN SON MAI, VAN.NAMAxMAS2, WHDFODS2PKSJDKS, XA/MINQIONGSHOP, XA/SANYATIANSTORE, Xiongxiang66058, YUANWEIMART, Yinyijun423, Yuruanmao-Co, Yydekzn, Yymarse, ZHONGSHENGMAMA, ZHUMUS, ariqiyan32447, babymilo, bang299popu, bomrjyngon, borubaihuo, chaochayouhua, chenbiaoshuiguoshanghang, chunlinwenjujiu11, daiwenjie41761, demgfjsnl, dongguanxieduofuzhuangyouxianzerengongsi, dongyimeng9995, dukun Store, foshanyujietingmaoyiyouxiangongsi, fucailing55189, fuhan182, fumingyue43831, gaohui231, gfdfbfdwqfgregtbg, glazingmotphvro, gongni fashion, guoliujiang20136, haikoushiyingchengshangmaoyouxiangongsi, haojianquan55206, henghongwenjujingyingbu, huangyong93688, huanping15804, ingtanhongdahaiyunyouxiangongsi, jinxiao35879, junfanwenjujingyingbu, khft19842, kongfanli48618, lichuang39796, licuicui5203, lidawen55888, lifengfe22805, lilianxi3572, linxinquanfuzhuangchang, linyu fashion, liruotong2042, lishengjiee, liuhaibin163, liujinyuan21395, liukaixin51062, liupenglong71665, liusanyuan1197, liuxishan22806, liwannan01561, liwenxang74380166, lixin71217, liyapeng1234, lizixuan1394, luhnmmivs, luoqi4455, mahua Store, maolei4150, mcshoofegcitg, mengkecen70328, menglili, nanding60483, niuzhi67664, pangmeili52607, peimengyue55108, puhaofei56950, qiuping65197, quyan08610, renqingmin51194, ryan williamsu, shangzhenfei3826, sksdjfsdhj, stenedchcj, stores keila, sunboyu58228, sunling5455, tanjianing0542, tea tea canvas poster, teatearlsmr, tjkethjewsrgsfr, uci292, unsqueezing, vyujkloi, wangchangqing01468, wangjiale555, wangshuang794684, wangxianghui39773, wangyingming6621, wangzezhong06926, weiqiumei226, wuming90212, wushuaihua05948, wuxingchi15114, xiaguoqiang01020, xiaxulan42671, xiayujia57514, xuyonghui53741, xuzhihong62097, yangjinyou1017, yangqing123, yanguofei49143, yangxuying3764, yanwenxue48580, yiwanbommQ, yueshuai59147, yuwanting30727, zhanghao15163, zhangjialiang76775, zhangnengyuan10950, zhangxiaoli11194, zhaojie76454, zhaoshi1234, zhengfhuai, zhengyuanxiang71068, zhongkaiqiang39593, zhouxiyu40247, zhuminggang17798 and terminating Yuzhengliu and licfjiedaolinchenwenjujingyingbu

[Amended] Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

MOTION by Plaintiff Motley Crue, Inc. for default judgment as to The Defendants Identified In [Amended] Schedule A

MEMORANDUM by Motley Crue, Inc. in support of motion for default judgment[40]

Exhibit 1

Exhibit 2

Exhibit 3

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith A. Vogt

MINUTE entry before the Honorable Joan B. Gottschall: Any response to plaintiff's motion 40 for entry of default and for entry of default judgment is due on or before January 31, 2023. The court will rule on the papers unless a hearing is requested on or before January 31, 2023. A hearing, to be conducted via teleconferencing, may be requested by sending a message to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and attorneys who have appeared. Plaintiff is ordered to serve defendants and any affected third-party providers with a copy of this order and file a certificate of service on or before January 19, 2023. Mailed notice

CERTIFICATE of Service by Plaintiff Motley Crue, Inc. regarding set motion and R&R deadlines/hearings, 42

MINUTE entry before the Honorable Joan B. Gottschall: The deadline of 1/31/2023 to object to plaintiff's motion for entry of default and default judgment has come and gone (see document nos. 42 and 43), and no objection has been filed. Plaintiff's motion 40 for entry of default and default judgment is granted. Enter default judgment. Civil case terminated. Mailed notice

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Joan B. Gottschall on 2/1/2023. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 168 Yuzhengliu

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a post-judgment notice 46 of voluntary dismissal of defendant no. 168 (Yuzhengliu). The notice is ineffective because judgment has been entered 45, and Fed. R. Civ. P. 41(a) does not authorize post-judgment voluntary dismissals. See Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 397 (1990). The Federal Rules of Civil Procedure provide several vehicles for obtaining relief from a judgment. See, e.g., Fed. R. Civ. P. 55(c), 59(e), 60. The court does not know why plaintiff is attempting to dismiss defendant no. 168. If plaintiff has settled with this defendant, the proper way to proceed is to file a motion under Federal Rule of Civil Procedure 60(b)(5), which permits the court to set aside a judgment if it "has been satisfied, released, or discharged." Mailed notice