2022-cv-06625

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 402, receipt number AILNDC-20083768.

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

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

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 1 - Parts 1-5 regarding complaint[1]

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Exhibit 1-4

(Exhibit 1-5)

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 Patents 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

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment.

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.

MAILED patent report to Patent Trademark Office, Alexandria VA

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable John Robert Blakey for all further proceedings pursuant to 28:294(b). Honorable Joan H. Lefkow no longer assigned to the case. Signed by Executive Committee on 11/29/2022.

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)

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 2 - Parts 1-5 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

(Exhibit 2-5)

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)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for leave to file 4, motion for miscellaneous relief 18 before Honorable John Robert Blakey on 12/20/2022 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Plaintiff has sued 142 online marketplaces alleging patent infringement [1] and seeking a temporary restraining order to enjoin sales of unauthorized products. Based upon its review of the materials submitted, the Court finds that Plaintiff's allegations support the joinder of Defendants in this single action. Plaintiff has alleged and established, via declaration [16], that the sellers identified on Schedule A "share unique identifiers, such as templates with common design elements that intentionally omit any contact information or other information for identifying Defendants or other Seller Aliases they operate or use"; that Defendants' stores "include other notable common features, such as use of the same registration patterns, accepted payment methods, check-out methods, keywords, advertising tactics, similarities in price and quantities, the same incorrect grammar and misspellings, and/or the use of the same text and images"; and that Defendants' products "bear similar irregularities and indicia of being unauthorized to one another, suggesting that the Infringing Products were manufactured by and come from a common source and that Defendants are interrelated." [16] 15. Plaintiff further alleges that Defendants work "in active concert to knowingly and willfully manufacture, import, distribute, offer for sale, and sell Infringing Products in the same transaction, occurrence, or series of transactions or occurrences." Id. 18. For present purposes, this satisfies the "series of transactions or occurrences" requirement of section 299(a)(1), as well as Fed. R. Civ. P. 20(a)(2), and Plaintiff may proceed against the identified Defendants in this single action. The Court grants Plaintiff's motion to seal [4] and motion for electronic service of process [18]. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order [13]. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 1/2/23. The 12/20/22 Notice of Motion date is stricken. Mailed notice

SEALED ORDER Signed by the Honorable John Robert Blakey on 12/19/2022. Mailed notice

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

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

MEMORANDUM by Dyson Technology Limited in support of extension of time[24]

Declaration of Jake M. Christensen

NOTICE of Motion by Jake Michael Christensen for presentment of extension of time[24] before Honorable John Robert Blakey on 12/29/2022 at 11:00 AM.

SURETY BOND in the amount of $ 10,000.00 posted by Dyson Technology Limited. (Document not imaged)

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's ex parte motion 24 to extend the temporary restraining order entered 12/19/22 23. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 1/16/23. The 12/29/22 Notice of Motion date is stricken. Mailed notice

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 Dyson Technology Limited as to certain Defendants

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

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction 31

Declaration of Jake M. Christensen

(Exhibit 1)

NOTICE of Motion by Jake Michael Christensen for presentment of motion for preliminary injunction 31 before Honorable John Robert Blakey on 1/11/2023 at 11:00 AM.

(Exhibit A)

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/6/2023, answer due 1/27/2023.

Declaration of Andrew D. Burnham

(Exhibit A)

MINUTE entry before the Honorable John Robert Blakey: Based upon the notice of dismissal [30], the Court dismisses this case without prejudice under Rule 41(a)(1) as to Defendants DZTQD (No. 36) and AutoKing-79 (No. 105). Absent reinstatement by 6/30/23, the dismissal of these Defendants shall automatically convert to a dismissal with prejudice. Mailed notice

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/11/2023, answer due 2/1/2023.

Declaration of Andrew D. Burnham

Exhibit A

MINUTE entry before the Honorable John Robert Blakey: In person motion hearing held on 1/11/2023. No defendant has filed an appearance in this matter or otherwise objected in response to the TRO or Plaintiff's motion for entry of a preliminary injunction [31]. Accordingly, and based upon the same findings made in this Court's TRO [23], this Court finds that a preliminary injunction is appropriate and warranted, as well as unopposed and grants Plaintiff's motion for preliminary injunction [31]. Enter Preliminary Injunction Order. The Court directs the Clerk 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. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Status hearing set for 2/23/2023 at 11:00 a.m. in Courtroom 1203. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable John Robert Blakey on 1/11/2023. Mailed notice

NEW PARTIES: 666, 703, 2FAMadODihN, A14XHVLDZMW9U3, A1HGGQIT3AE5BY, A20I457VQHOPYU, A2B5FMFH46XZLV, A2RATA8W60UF4B, A2Y7B518YSYL6F, A2YGADES8MID7V, A3FI14J2QKA94H, A3M9XRNSKKH6Y9, A3VHD3LV7U2I9P, A8N0RDV4970GZ, A9289YK8QKD9J, ACH9CS69HPZQN, anyanghoulifeng, BCTDSWZ, BettyLove520, bianchunyubkeogo, BIN LEE TRADING LIMITED, Chen Crystal Shop, chenshuaidedianabc, ChirRayDirect, Conderson, DZTQD, gedierabolaitijingpindian, GGYYT, GOOD Y, gregbfdfdsewq, guodoudou, haikoushichenyuyishangmaoshanghang, haikoushikuiyishangmaoshanghanggerenduzi, haikoushitangkaixuandedian, HIGHQUASHOP, huangbaodong896, huihui6123, HYZBZJ, Integritybusiness, JiaBin-AMZ, JINYUBAIHUO, keturanhuixiangqilequanbu, kukou, LANG, Leonardo5566, LHXLHX, Li kezhi store, LIANQINGBAIHUO, limengyaohgfb), LiMingBo, LINTIANGUIG, lixiangjundedian, Lost Wonderland Flagship Store, LSXING, lulu--shop, Obaok, OHm0iyJEo6, OYYOo, panjiqumaishibaihuoshanghang, QIANFEIBAIHUO, qiangzedianzishangwuxiaoshoubu, qianjinhezuxiyishigunanqiu, renxiaoyao, ridenima, SGSX1, shangchengxianwenyoudian, shangchengxianyonshengbaihuochaoshi, shangchengxianzhenzhen, shanxiniugekejiyouxiangongsi, shanxiyilanakejiyouxiangongsi8754, SHENJUNBAIHUO, Shining&Isabella, shuangjiajianzhukejiyouxiangongsi, tengzhizhou, tianbangshop, tianjinzhongzhuoshangmaozhongxin, univer, US-juanjuan, US-wenlei, uxinxis, vcxgdvcxnmyukij, weichengnan, wk006, Wuyhj, wuyuezhidgr161, WYTHLHAOXUAN, xianqujiangxinquxiaolongshangmaochang, XINLIZB, YaoChuBaiHuo, yaqian-ksad, YLHY, YunBoxiaodina, Zheng family property, aenuama, AutoKing-79, bababobo00712, diss4202, kkti84, liaiai200147, pe467837, rylnis, tenflyer666, yitong-store, Adslk, BesBuy Direct, Beyourguard, Big space, Dallas, Dongganshilongzhendianzikejiyouxiangongsi, Dongguan yongce Electronic Technology Co., Ltd, GONGYIHONG, Guangzhou East Village Technology Co., Ltd, Huanxu Co,Ltd, hui zhou shi wen li wen ju you xian gong si, JTZC TECK, Klestintis, Kody.llc, Lang Tuo, LIUCHANGLC, Miekor, shenzhen aiqianfu e-commerce Co.,Ltd, shenzhenshixuesidianzishangwuyouxiangongsi, SIGuang, UISHUSO, xiaocheng, xiaofu, YeekTok, Yezyy, niuchengrong1134, nvjiaoezimei, peterxie, quanzhoukaiyu, Aimee Hedghog Store, Global Seal Store, Hair Salon BT Store, Juxingtrade Store, Lucky little mushroom Store, PENGNIAO Global Store, Shop1100247171 Store, XunMei Store, XYJD Small Appliances Store and ZenFuRui-17 Store added to case caption.

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

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of dismissal [40], Defendants bababobo00712 and shenzhenshixuesidianzishangwuyouxiangongsi are dismissed without prejudice with leave to reinstate within 270 days of the entry of this order. Mailed notice

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

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal [42], this case is dismissed without prejudice as to Defendants AutoKing-79, diss4202, pe467837, rylnis, Huanzu Co,Ltd and Miekor. Absent reinstatement on or before 270 days of this order, the dismissal will convert to one with prejudice without further order of the Court. Mailed notice

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

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal [44], this case is dismissed without prejudice as to Defendants guodoudou, kkti84, Dallas and Dongganshilongzhendianzikejiyouxiangongsi. Absent reinstatement on or before 270 days of this order, the dismissal will convert to one with prejudice without further order of the Court. Mailed notice

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

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal [46], this case is dismissed without prejudice as to Defendants uxinxis, JTZC TECK, Kody.llc, SIGuang and YeekTok. Absent reinstatement on or before 270 days, the dismissal will convert to one with prejudice without further order of the Court. 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[48]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[49]

Exhibit 1

NOTICE of Motion by Jake Michael Christensen for presentment of motion for entry of default, motion for default judgment[48] before Honorable John Robert Blakey on 2/22/2023 at 11:00 AM.

Exhibit A

MINUTE entry before the Honorable John Robert Blakey:The Court strikes the 2/22/23 Notice of Motion date and 2/23/2023 status and resets the hearing on Plaintiff's motion for default and default judgment 48 for 3/2/23 at 11:00 a.m. in Courtroom 1203. Mailed notice

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

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's notice of dismissal [53], the Court hereby dismisses this case without prejudice as to Defendants GONGYIHONG (No. 121) and hui zhou shi wen li wen ju you xian gong si (No. 124). Absent reinstatement by 11/22/23, this dismissal shall automatically convert to a dismissal with prejudice. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: In person motion hearing held on 3/2/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for entry of default judgment 48 is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER Signed by the Honorable John Robert Blakey on 3/2/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order 56 in the amount of the Judgment Amount as to certain defendants

FULL SATISFACTION of Judgment regarding order 56 in the amount of the Judgment Amount as to certain defendant

FULL SATISFACTION of Judgment regarding order 56 in the amount of the Judgment Amount as to certain defendants

FULL SATISFACTION of Judgment regarding order[56] in the amount of the Judgment Amount as to certain defendant