2022-cv-06758

COMPLAINT filed by Bigfoot 4x4, Inc.; Jury Demand. Filing fee $ 402, receipt number AILNDC-20100182.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Robert Payton Mcmurray

MOTION by Plaintiff Bigfoot 4x4, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bigfoot 4x4, Inc.

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (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. (Text entry; no document attached.)

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bigfoot 4x4, Inc. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for temporary restraining order, 10

Declaration Trent Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 1 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 2 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 3 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 4 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 5 of Trent Declaration

Notice of Claims Involving Trademarks by Bigfoot 4x4, Inc.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

((List of Trademarks Exhibit 1))

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MINUTE entry before the Honorable Martha M. Pacold: For the reasons set forth in plaintiff's motions (6, 9, 10), the supporting memorandum 11 and the temporary restraining order, plaintiff's motions for leave to file under seal 6 and for leave to file excess pages 9 are granted. Plaintiff's motion for a temporary restraining order, including a temporary injunction, a temporary transfer of defendant domain names, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 10 is granted, except to the extent that the motion seeks a temporary transfer of defendants' internet stores. 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, but at this preliminary stage, 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.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Martha M. Pacold on 12/5/2022:

SURETY BOND in the amount of $ 10,000.00 posted by Bigfoot 4x4, Inc. (Document not scanned.)

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's ex parte motion to extend the Temporary Restraining Order 23 is granted. Under Rule 65(b)(2), the court finds good cause to extend the TRO for 14 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 21 entered on 12/05/2022 is extended until 01/02/2023.

ATTORNEY Appearance for Defendants HobbyPark-US, Aoxinfa-US, TianqlUS by Yizhou Liu

MOTION by Plaintiff Bigfoot 4x4, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for preliminary injunction 26

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 26

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

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to seal document Memorandum in Support of Motion to Dissolve and Opposition to Motion for Preliminary Injunction and Supporting Exhibits

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS for order Dissolving Ex Parte Temporary Restraining Order

SEALED DOCUMENT by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS Memorandum in Support of Motion Under Rule 65 to Dissolve Ex Parte Temporary Restraining Order/Emergency Opposition to Motion for Entry of a Preliminary Injunction 26 Modified on 12/30/2022.

Exhibit A (Liu Declaration)

Exhibit A-1 (Email Thread)

Exhibit A-2 (Notice of Service)

Exhibit B (Sun Declaration)

Exhibit C (Xie Declaration)

(Exhibit D (Tang Declaration))

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion for order 30 Dissolving Ex Parte Temporary Restraining Order/Emergency Opposition to Motion for Entry of a Preliminary Injunction 26 Modified on 12/30/2022.

Exhibit A (Liu Declaration)

Exhibit A-1 (Email Thread)

Exhibit A-2 (Notice of Service)

Exhibit B (Sun Declaration)

Exhibit C (Xie Declaration)

(Exhibit D (Tang Declaration))

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff shall serve defendants with this notice. The court has taken the motion for preliminary injunction 26 under advisement and will consider the motion unopposed if no defendant appears and objects by 1/27/2023.

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.

CERTIFICATE of Service by Plaintiff Bigfoot 4x4, Inc.

ATTORNEY Appearance for Defendants Aoxinfa-US, HobbyPark-US, TianqlUS by Steven P. Mandell

ATTORNEY Appearance for Defendants ACEKEEPS HOBBIES, AIMROCK HOBBIES by Ge Lei

MINUTE entry before the Honorable Martha M. Pacold: The motion to seal filed by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS 29 is granted. To the extent those defendants' motion seeks to dissolve the temporary restraining order, 30 it is denied as moot. Per the court's order on 12/15/2022, the temporary restraining order expired on 1/2/2023, 24, and has not been extended past that date. The court has received and will consider the opposition to the entry of a preliminary injunction filed by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS 30. Plaintiff's reply in support of its motion for preliminary injunction is due by 2/3/2023.

RESPONSE by ACEKEEPS HOBBIES, AIMROCK HOBBIESin Opposition to MOTION by Plaintiff Bigfoot 4x4, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction 26

ATTORNEY Appearance for Defendants Aoxinfa-US, HobbyPark-US, TianqlUS by Andrew W. Alexander

ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by Aoxinfa-US against Bigfoot 4x4, Inc. by Aoxinfa-US

(Exhibit A (email thread))

ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by HobbyPark-US against Bigfoot 4x4, Inc. by HobbyPark-US

(Exhibit A (email thread))

ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by TianqlUS against Bigfoot 4x4, Inc. by TianqlUS

(Exhibit A (email thread))

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Plaintiff's Motion for Leave to File an Amended Schedule A

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to file an amended Schedule A 44 is granted. Defendants No. 2 chaoxin66, No. 11 yueyichao1, No. 21 arhanshop20218, No. 22 arya.a, No. 24 besteast2021, No. 30 flying_wings, No. 33 gra-402545, No. 37 inyoung_de, No. 38 kollector15610, No. 39 niiya_2017, No. 47 wadgngojhui, No. 100 Huailuoshangmao, No. 104 jiuwu, No. 113 RCMOXETO, No. 114 RCStation, No. 118 Speedy Racing, No. 121 Uncus, No. 122 Vgoodhobby, No. 134 zhoukoushihuaiyangqudaishengbaihuolingshoudian, No. 136 AKASO PROFESSIONAL SELLER, No. 137 Better and Easy Life, No. 148 TOUMENY, No. 149 Trendy Mall, are dismissed with prejudice and each party shall bear its own attorney's fees and costs. Plaintiff is directed to file an amended Schedule A on the docket by 2/3/2023.

ATTORNEY Appearance for Defendants Aoxinfa-US, HobbyPark-US, TianqlUS by Todd R Tucker

NOTICE by Bigfoot 4x4, Inc. Notice of Filing

(Amended Schedule A)

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Reply in Support of its Motion for Entry of a Preliminary Injunction [Dkt. No. 38]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's unopposed motion for an extension of time 48 is granted. Plaintiff's reply in support of its motion for preliminary injunction 26 as to defendants No. 77 "Aoxinfa-US", 99 "HobbyPark-US," and 119 "TianqlUS" is due 2/10/2023.

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to compel Service of Sealed Documents

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion to compel 50 Service of Sealed Documents

Exhibit A (List of Schedule A Cases)

(Exhibit B (1-20-23 Email Thread))

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's response to Defendants' No. 77 "Aoxinfa-US", 99 "HobbyPark-US," and 119 "TianqlUS" motion to compel 50 is due by 2/22/2023. Any reply in support of the motion to compel is due by 3/1/2023.

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Counterclaim

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Counterclaim

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Counterclaim

ATTORNEY Appearance for Defendants Cybiufam-US, Majuexid-US, C9Dshop, Jekentib, casualittier-US, Gongloian-US, Wecrun-US by Christopher Paul Keleher

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a Second Extension of Time to File a Reply in Support of Its Motion for Entry of a Preliminary Injunction [Dkt. No. 38]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's unopposed motion for extension of time 57 is granted. Plaintiff's reply in support of its motion for preliminary injunction 26 as to defendants No. 77 Aoxinfa-US, 99 HobbyPark-US, and 119 TianqlUS is due by 2/17/2023.

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion to Dissolve the Temporary Restraining Order and Reply in Support of Entry of a Preliminary Injunction

Exhibit A

Exhibit B

Exhibit C

(Exhibit D)

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Plaintiff's Motion for Leave to File an Amended Schedule A

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Plaintiff's Second Motion for Leave to File an Amended Schedule A

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion to Compel Service of Sealed Documents

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to exceed page limitation 59 is granted. Plaintiff's oversized brief is already filed on the docket at 60.

MINUTE entry before the Honorable Martha M. Pacold: Plainiff's motion for leave to file an amended Schedule A 61 is granted. The defendants listed in this motion 61 are dismissed with prejudice and each party shall bear its own attorney's fees and costs. Plaintiff's motion for leave to file an amended Schedule A 62 is granted. The defendants listed in this motion 62 are dismissed without prejudice and each party shall bear its own attorney's fees and costs. Plaintiff is directed to file a single amended Schedule A form on the docket by 3/3/2023 identifying the remaining defendants.

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS for Leave to File Under Seal

SEALED MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS for Leave to File Surreply in Support of Opposition to Motion for Entry of a Preliminary Injunction

Exhibit A - Defendants' [Proposed] Surreply in Support of Opposition to Motion for Entry of a Preliminary Injunction

Exhibit A to Proposed Surreply - SEALED Sun Decl.

Exhibit B to Proposed Surreply - SEALED Xie Decl.

(Exhibit C to Proposed Surreply - SEALED Tang Decl.)

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUSfor Leave to File Surreply in Support of Opposition to Motion for Entry of a Preliminary Injunction

Exhibit A - Defendants' [Proposed] Surreply in Support of Opposition to Motion for Entry of a Preliminary Injunction

Exhibit A to Proposed Surreply - REDACTED Sun Decl.

Exhibit B to Proposed Surreply - REDACTED Xie Decl.

(Exhibit C to Proposed Surreply - REDACTED Tang Decl.)

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS for attorney fees

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion for attorney fees 69

FIRST AMENDED ANSWER to Complaint with Jury Demand, FIRST AMENDED COUNTERCLAIM filed by HobbyPark-US against HobbyPark-US. by HobbyPark-US

FIRST AMENDED ANSWER to Complaint with Jury Demand, FIRST AMENDED COUNTERCLAIM filed by Aoxinfa-US against Aoxinfa-US. by Aoxinfa-US

FIRST AMENDED ANSWER to Complaint with Jury Demand, FIRST AMENDED COUNTERCLAIM filed by TianqlUS against TianqlUS. by TianqlUS

NOTICE by Bigfoot 4x4, Inc. Notice of Filing

(Amended Schedule A)

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Motion for Leave to File an Amended Schedule A

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Motion for Leave to File an Amended Schedule A

ANSWER to Complaint with Jury Demand AFFIRMATIVE DEFENSES, COUNTERCLAIM filed by AIMROCK HOBBIES, ACEKEEPS HOBBIES against Bigfoot 4x4, Inc. by AIMROCK HOBBIES, ACEKEEPS HOBBIES

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motions for leave to amend the pleadings 75, 76, are granted. Plaintiff is directed to file the amended Schedule A separately on the docket by 3/20/2023. With respect to Plaintiff's motion for a preliminary injunction, 26, if Plaintiff continues to seek this relief, Plaintiff is instructed to submit, by 3/20/2023, a new proposed preliminary injunction order in light of the amended schedule A.

MINUTE entry before the Honorable Martha M. Pacold: The motion to file under seal by Shenzhen Daoen Model Technology Co., Ltd., Shenzhen Aoxinfa Technology Co., Ltd., and Shenzhen Tianqinli Technology Co., Ltd. 66 is granted. The motion for leave to file a surreply 67 is granted. Defendants are directed to file the surreply separately on the docket by 3/20/2023.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's response to defendants' motion for costs, expenses, and fees 69 is due by 3/27/2023. Defendants' reply is due by 4/3/2023.

SEALED DOCUMENT by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS Amended Surreply in Support of Opposition to Motion for Entry of a Preliminary Injunction

NOTICE by Bigfoot 4x4, Inc. Notice of Filing

(Amended Schedule A)

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Amended Counterclaims

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Amended Counterclaims

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Amended Counterclaims

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Response to Defendant's Motion for Costs, Expenses, and Fees [Dkt. Nos. 69, 70]

SUMMONS Returned Executed by Bigfoot 4x4, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 12/28/2022, answer due 1/18/2023.

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Answer to Defendant's Counterclaims

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's unopposed motion for a first extension of time to file a response to defendants' motion for costs, expenses, and fees 86 is granted. Plaintiff's response to Defendants' motion for costs, expenses, and fees 69 is due by 3/31/2023. Defendants' reply is due by 4/10/2023.

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion for Costs, Expenses and Fees

Exhibit A

Declaration Kalbac Declaration

(Exhibit B)

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to file an oversized brief 90 is granted. The brief is already filed as a separate entry on the docket. 91.

REPLY by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to Response 91 to Defendants' Motion for Costs, Expenses, and Fees

ATTORNEY Appearance for Defendant VASTSEE (154) by Michael Thomas Stanley

MOTION by Defendant VASTSEE (154) for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Martha M. Pacold: Defendant Vastsee's motion for an extension of time 95 is granted. Defendant Vastsee to answer or otherwise respond to the complaint by 5/4/2023.

MOTION by Defendant VASTSEE (154) for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Martha M. Pacold: Defendant Vastsee's motion for an extension of time 97 is granted. Defendant Vastsee to answer or otherwise respond to the complaint by 5/25/2023.

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to compel Responses to Discovery Requests and for Fees

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion to compel 99 Responses to Discovery Requests and for Fees

Exhibit A (Discovery Requests)

(Exhibit B (Alexander Declaration))

MINUTE entry before the Honorable Martha M. Pacold: The court previously directed that if plaintiff continued to seek a preliminary injunction (in plaintiff's motion for preliminary injunction 26), plaintiff should submit by 3/20/2023 a new proposed preliminary injunction order in light of the amended schedule A. 78. Plaintiff did not comply. If plaintiff continues to seek a preliminary injunction, by noon on 6/1/2023, plaintiff should file on the docket (and send Word version to the proposed order inbox) (1) an updated proposed preliminary injunction order attaching (2) an updated schedule A. Both the updated proposed preliminary injunction order itself and the attached updated schedule A must (1) include only nonappearing defendants that remain in the case, (2) clearly exempt any dismissed defendants, and (3) clearly exempt any defendants that have appeared as of 5/30/2023. As to any defendants that have appeared as of 5/30/2023, the preliminary injunction motion will be continued.

STATUS Report by Bigfoot 4x4, Inc.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's status report, 102, and updated proposed preliminary injunction order reflect that the only remaining defendants in this case are Aoxinfa-US, HobbyPark-US, TianqlUS. Those defendants have appeared and opposed plaintiff's motion for a preliminary injunction. See 30. The preliminary injunction motion is therefore continued. See 101.

EXECUTIVE COMMITTEE ORDER: It appearing that General Order 23-0023 was entered on June 2, 2023, identifying the cases to form the initial calendar of the Hon. LaShonda A. Hunt; therefore It is hereby ordered that the Clerk of Court shall reassign the list of cases below from each district judge that were reassigned in error to Judge Hunt; and It is further ordered that the Clerk of Court shall reassign the replacement cases that were identified from each judges' secondary list to Judge Hunt. Case reassigned to the Honorable LaShonda A. Hunt for all further proceedings. Honorable Martha M. Pacold no longer assigned to the case. Signed by Honorable Rebecca R. Pallmeyer on 06/05/2023.

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. A telephonic status hearing is set for 6/20/23 at 10:00 a.m. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: 877-336-1828, Access Code: 4082461. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice.

MINUTE entry before the Honorable LaShonda A. Hunt: Status hearing held with counsel for Plaintiff and the remaining Defendants present. For the reasons discussed in open court, this case is referred to the Magistrate Judge for settlement, ruling on Plaintiff's motion for preliminary injunction 26, ruling on the pending discovery motions [50, 69, 99], and discovery supervision with the authority to set, extend, and adjust all discovery deadlines. Emailed notice.

EXECUTIVE COMMITTEE ORDER: Case referred to the Honorable Jeffrey T. Gilbert, pursuant to Local Rule 72.1. Signed by Executive Committee on 6/21/2023.

MINUTE entry before the Honorable Jeffrey T. Gilbert: This case has been referred to Magistrate Judge Gilbert for the purposes of ruling on Plaintiff's motion for preliminary injunction 26, ruling on the pending discovery motions 50, 69, 99, and discovery supervision with the authority to set, extend, and adjust all discovery deadlines. A telephone status conference with the Court is set for 6/29/23 at 11:00 a.m. The call-in number is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 6/29/23. At Plaintiff's request, Plaintiff's Motion for Entry of a Preliminary Injunction 26 is withdrawn. Defendants' Motion to Compel Service of Sealed Documents 50 is denied as moot for the reasons stated on the record. Plaintiff's oral request for extension of time to respond to Defendants' discovery requests is denied without prejudice for the reasons stated on the record. The Court sets the following briefing schedule on Daoen Defendants' Motion to Compel Responses to Discovery Requests and for Fees 99 : Response due by 7/20/23. Reply due by 7/27/23. A telephone status hearing and possible ruling on Defendants' Motion to Compel 99 is set for 8/24/23 at 9:45 a.m. By 12:00 p.m. on 7/12/23, Plaintiff and all remaining Defendants or Counter-Plaintiffs shall file a joint report that includes a proposed discovery schedule and plan. The report should indicate whether any more written discovery needs to be served, and if so, when that discovery will be served; include the parties' best estimate of the number of depositions that will need to be taken by any party based on the information then available to the parties; whether there are any disputes as to the location of any depositions and, if so, how the parties propose to resolve those disputes; and a proposed fact discovery close date. The parties' joint report also should state whether any party intends to make Rule 26(a)(2) disclosures and, if so, propose a schedule for expert discovery. Upon reflection, the Court wants to set a status hearing as soon as possible after it receives the parties' proposed discovery schedule and plan. Accordingly, a telephone status hearing is set for 7/13/23 at 1:30 p.m. The call-in number for the hearings on 7/13/23 and 8/24/23 is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Unopposed Motion to Change the Hearing Date Presented before Presiding Judge

STATUS Report Joint Status Report by Bigfoot 4x4, Inc. Presented before Presiding Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Unopposed Motion to Change Hearing Date 110 is granted. The telephone status hearing set for 7/13/23 is stricken and reset to 7/18/23 at 10:00 a.m. The call-in number for the hearing on 7/18/23 is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 7/18/23. The Court reviewed the parties' Joint Status Report 111. Plaintiff represents it intends to respond to the Daoen Defendants' interrogatories and requests for production of documents this week. The briefing schedule on the Daoen Defendants' Motion to Compel Responses to Discovery Requests and for Fees 99 shall stand 109. The Court enters the following discovery schedule with respect to Plaintiff and the Daoen Defendants consistent with the parties' Status Report 111 and the discussion held on the record: Plaintiff shall serve any written discovery it intends to serve on the Daoen Defendants by 7/25/23. (The Daoen Defendants previously served written discovery on Plaintiff 99. Fact discovery shall be completed by 9/1/23. The parties' Rule 26(a)(2) experts shall be disclosed by 9/25/23. The parties' Rule 26(a)(2) expert reports shall be disclosed by 10/13/23. Rebuttal expert reports shall be disclosed by 11/10/23. Expert discovery, including expert depositions, shall be completed by 12/1/23. By 8/2/23, Plaintiff and the Daoen Defendants file a joint status report that contains a schedule of confirmed dates for any depositions that shall be taken by either side prior to the close of fact discovery, and states the locations of those depositions. If there are any disagreements regarding the location of a deposition, then the status report should explain each side's position. The Court enters the following discovery schedule with respect to Plaintiff and Defendant Aimrock Hobbies and Acekeeps Hobbies: Written discovery shall be served by 9/1/23. Fact discovery shall be completed by 1/12/24. The parties' Rule 26(a)(2) experts shall be disclosed by 2/23/24. The parties' Rule 26(a)(2) expert reports shall be disclosed by 3/29/24. Rebuttal expert reports shall be disclosed by 4/19/24. Expert discovery, including expert depositions, shall be completed by 5/3/24. With the agreement of all parties, the Court sets the following dates for the exchange of settlement letters: By 7/25/23, the Daoen Defendants shall send a settlement demand letter to Plaintiff that includes these Defendants monetary and non-monetary demands, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Plaintiff shall respond by 8/2/23, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Defendants Aimrock Hobbies and Acekeeps Hobbies shall send a settlement demand letter on their counterclaim to Plaintiff by 7/25/23, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Plaintiff shall respond by 8/2/23, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. The parties and counsel are directed to the Court's Standing Order for Settlement Conference posted on the Court's website www.ilnd.uscourts.gov/Judges with respect to their settlement letters. Counsel should note that Order requires them to provide a copy of the Order to their clients. A continued telephone status hearing and hearing on the Motion to Compel 99 is set for 8/15/23 at 10:30 a.m. The telephone status hearing set for 8/24/23 is stricken with no appearance required. The call-in number for the hearing on 8/15/23 is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion to Compel Discovery Responses and for Attorney Fees

RESPONSE by Aoxinfa-US, HobbyPark-US, TianqlUSin Support of MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to compel Responses to Discovery Requests and for Fees 99

Exhibit A (Bigfoot Responses to Hobbypark ROGs

Exhibit B (Bigfoot Responses to Hobbypark RFPs

Exhibit C (Kalbac Email)

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS for protective order (Joint Agreed Protective Order) Presented before Magistrate Judge

Exhibit A (Proposed Protective Order)

Exhibit B (Redlined Protective Order)

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Joint Status Report and Plaintiff's Response to Defendants' Settlement Demands Presented before District Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Joint Motion for Entry of Agreed Protective Order 116 is granted. Mailed notice

AGREED PROTECTIVE Order. Signed by the Honorable Jeffrey T. Gilbert on 8/3/2023. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Unopposed Motion for a First Extension of Time to File a Joint Status Report and Plaintiff's Response to Defendants' Settlement Demands 117 is granted. The deadline for Plaintiff and Defendant Nos. 77 "Aoxinfa-US", 99 "HobbyPark-US" and 119 "TianqlUS" to file a joint status report is extended to 8/3/23. Plaintiff shall respond to Defendants' settlement demands by 8/3/23, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Mailed notice

STATUS Report Regarding Depositions by Aoxinfa-US, HobbyPark-US, TianqlUS Presented before Magistrate Judge

TRANSCRIPT OF PROCEEDINGS held on 7/18/23 before the Honorable Jeffrey T. Gilbert. Order Number: 46367. Court Reporter Contact Information: Kathleen_Fennell@ilnd.uscourts.gov. 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 9/5/2023. Redacted Transcript Deadline set for 9/15/2023. Release of Transcript Restriction set for 11/13/2023.

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status and motion hearing held on 8/15/23. Daoen Defendants' Motion to Compel Responses to Discovery Requests and for Fees 99 is granted in part for the reasons stated on the record. The Court overrules certain of Plaintiff's objections and orders Plaintiff to serve amended responses to the requests for production and interrogatories that eliminate the objections that the Court overruled, and produce the relevant, responsive, and non-privileged documents it plans to produce, by 8/30/23. Plaintiff also shall make a better attempt to respond to these Defendants' written discovery in compliance with the Federal Rules of Civil Procedure consistent with the Court's guidance during today's hearing. By 8/30/23, Defendants shall file an itemization of fees being requested in their Motion for Costs, Expenses, and Fees 69 and their Motion to Compel Responses to Discovery Requests and for Fees 99. Plaintiff shall respond by 9/6/23. Defendants shall reply by 9/13/23. The Court reviewed the parties' Joint Status Report 121. The parties shall file an updated joint status report by 9/20/23 that includes an update on these parties' progress with written discovery. With respect to settlement, Plaintiff shall respond to Daoen Defendants' settlement letter by noon on 8/22/23, with a copy delivered to the Court via the Court's settlement correspondence email at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Plaintiff' settlement letter should take into account to the Court's guidance and Defendants' request for an itemized settlement offer. Also by noon on 8/22/23, Plaintiff shall respond to Defendants Aimrock Hobbies and Acekeeps Hobbies letter, with a copy delivered to the Court via the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. A telephone status hearing is set for 8/30/23 at 10:30 a.m. to discuss whether settlement is a realistic possibility. The call-in number is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. Agreed Motion for Entry of Consent Judgment Presented before District Judge

Itemization of Fees Requested in Motion for Costs, Expenses, and Fees by Aoxinfa-US, HobbyPark-US, TianqlUS

(Exhibit A (Alexander Declaration))

Itemization of Fees Requested in Motion to Compel Responses to Discovery Requests and for Fees by Aoxinfa-US, HobbyPark-US, TianqlUS

(Exhibit A (Alexander Declaration))

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 8/30/23. Plaintiff and Daoen Defendants' oral motion to extend the fact discovery close date to 10/2/23 is granted for good cause shown as discussed on the record. These parties' Rule 26(a)(2) experts shall be disclosed by 11/2/23. Their Rule 26(a)(2) expert reports shall be disclosed by 12/4/23. Rebuttal expert reports shall be disclosed by 1/4/24. Expert discovery as betweeen these parties, including expert depositions, shall be completed by 2/5/24. Plaintiff and the Daoen Defendants shall file a status report by 10/5/23 that either confirms that fact discovery is closed as between these parties or provides any information to the Court that is necessary for case management. The parties' report should also inform the Court whether the parties intend to make Rule 26(a)(2) expert disclosures in accordance with the schedule previously set. Plaintiff and Defendants Aimrock Hobbies and Acekeeps Hobbies shall file a joint status report by 10/25/23 concerning the status of written discovery as between these parties, including whether responses to interrogatories and requests for production have been served; whether all responsive, relevant, and non-privilege documents that the parties intend to produce have been produced; whether there are any discovery disputes that the parties anticipate bringing before the Court after their Local Rule 37.2 discussions; and the identity of all witnesses that either side then intends to depose before the close of fact discovery. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [DKT. NO. 99] Presented before District Judge

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a Second Extension of Time to file a Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [Dkt. No. 99] Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Unopposed Motion for a First Extension of Time to File a Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [Dkt. No. 99] 128 and Plaintiff's Unopposed Motion for a Second Extension of Time to file a Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [Dkt. No. 99] 129 are granted. Plaintiff shall respond by 9/12/23. Defendants shall reply by 9/19/23. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Opposed Motion for a Third Extension of Time to File a Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [DKT. NO. 99] Presented before Magistrate Judge

CONSENT JUDGMENT Signed by the Honorable LaShonda A. Hunt on September 14, 2023. Emailed notice.

MINUTE entry before the Honorable LaShonda A. Hunt: Agreed Motion for Entry of Consent Judgment 124 is granted. Emailed notice.

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion for Costs, Expenses and Fees [Dkt. No. 69] and Motion to Compel Responses to Discovery Requests and for Fees [DKT. NO. 99]

TRANSCRIPT OF PROCEEDINGS held on 08/15/23 before the Honorable Jeffrey T. Gilbert. Order Number: 46570. Court Reporter Contact Information: Patrick Mullen, (312) 435-5565, patrick_mullen@ilnd.uscourts.gov. 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 10/11/2023. Redacted Transcript Deadline set for 10/23/2023. Release of Transcript Restriction set for 12/19/2023.

STATUS Report Joint Status Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court reviewed the parties' Joint Status Report 136. The Court grants the joint request of Plaintiff and the Daoen Defendants to extend the fact discovery date as to those parties to 10/31/23 so they can review responses to recently served discovery requests and/or requests for admission and continue to attempt to resolve the case. The dates previously set for expert discovery 127 will remain the same for now. The Court is not inclined to continue to extend the fact discovery close date indefinitely as between these parties based simply on speculation that they may be able to resolve the case. Plaintiff and the Daoen Defendants shall file a joint status report by 10/16/23 that contains the following information: (1) the status of their respective responses to written discovery and requests for admissions; (2) the status of their settlement efforts; and (3) confirmed dates for all remaining fact depositions that either side intends to take before the close of fact discovery including the deposition of Plaintiff's CEO. Mailed notice

REPLY by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to other 125, other 126 in Support of Itemizations of Fees

Exhibit A (Tucker Declaration)

Exhibit B (Motorola v. Hytera Opinion)

(Exhibit C (AIPLA Report Excerpts))

STATUS Report (Joint) by Aoxinfa-US, HobbyPark-US, TianqlUS Presented before Magistrate Judge

STATUS Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Opposed Third Motion to Extend Discovery Deadlines Presented before Magistrate Judge

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to compel Compliance with Third Party Subpoena of Michael Hierl Presented before Magistrate Judge

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion to compel 142 Compliance with Third Party Subpoena of Michael Hierl

Exhibit A (Hierl Deposition Notice)

Exhibit B (8-2 - 8-8 Emails)

Exhibit C (Hierl 8-10 Emails)

Exhibit D (8-29 Email Thread)

Exhibit E (9-1, 9-28, 10-3 Emails)

Exhibit F (Hierl Subpoena and Proof of Service)

(Exhibit G (Hierl 10-26 Letter))

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Opposed Third Motion to Extend Discovery Deadlines 141 is set for a telephone hearing on 11/14/23 at 10:30 a.m. The Daoen Defendants shall respond to Plaintiff's Motion 141 on or before 11/6/23. Plaintiff shall file its reply in support of its Motion by 11/9/23. Plaintiff and the Daoen Defendants should continue their efforts to schedule fact witness depositions that still remain to be taken conditioned upon the Court extending the fact discovery close date nunc pro tunc to 10/31/23 if the Court were to grant Plaintiff's Motion 141, which the Court has not yet decided to do. The Court hereby grants the parties leave to conduct any fact depositions they can agree to take prior to the 11/14/23 motion hearing date despite the expiration of the fact discovery period on 10/31/23. Also on 11/9/23, the parties shall file a short joint status report with the following information, if it is not contained in the briefing on Plaintiff's Motion 141 : (a) what written discovery requests remain outstanding in the sense that the responding party has not yet fully responded and/or the parties have not completed the Local Rule 37 process as to those requests; (b) when did Plaintiff first request or notice the depositions it still wants to take, how did the Daoen Defendants respond, and why were the depositions not calendared or taken before 10/31/23; and (c) confirmed dates for any remaining fact witness depositions that need to be taken assuming the Court were to extend the 10/31/23 fact discovery close date. The call-in number is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court sets the following briefing schedule on the Daoen Defendants' Opposed Motion to Compel Compliance with Deposition Subpoena to Michael Hierl and Award Fees and Costs 142 : Response due by 11/8/23. Reply due by 11/15/23. Mailed notice

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in Opposition to extension of time 141

Exhibit A (7-25 Email Thread)

Exhibit B (Notices of Deposition)

Exhibit C (8-11 Email Thread)

Exhibit D (8-30 Email Thread)

Exhibit E (10-30 Email Thread)

Exhibit F (10-20 Email Thread)

(Exhibit G (11-1 Email Thread))

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Response of Bigfoot 4x4, Inc. to Defendants' Motion to Compel the Deposition of Counsel for Bigfoot 4x4, Inc., Michael A. Hierl, and Motion to Quash Subpoena Modified on 4/1/2024.

(Exhibit 1)

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Opposed Motion for a First Extension of Time to File a Reply in Support of Plaintiff's Motion to Extend Discovery Deadlines [Dkt. No. 141] Presented before Magistrate Judge

STATUS Report by Aoxinfa-US, HobbyPark-US, TianqlUS Presented before Magistrate Judge

Exhibit A (10-14-23 Email)

Exhibit B (filed under seal)

(Exhibit C (11-9-23 Email))

SEALED DOCUMENT by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS Exhibit B to Joint Status Report

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to seal document sealed document 150 Presented before Magistrate Judge

Notice of Non-Opposition to Bigfoot's Motion for Extension to File Reply by Aoxinfa-US, HobbyPark-US, TianqlUS

(Exhibit A (11-9-23 Email))

STATUS Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Motion for a First Extension of Time to File a Status Report [DKT. NO. 144]. Presented before Magistrate Judge

REPLY by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Reply in Support of its Motion to Extend Discovery Deadlines

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Motion for a First Extension of Time to File a Status Report 154 is granted nunc pro tunc to 11/10/23. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Motion for a First Extension of Time to File a Reply in Support of Plaintiff's Motion to Extend Discovery Deadlines 148 is granted to 11/13/23 without objection from Daoen Defendants 152. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status and motion hearing held on 11/14/23. Plaintiff's Opposed Third Motion to Extend Discovery Deadlines 141 is denied for the reasons stated on the record. Discovery is closed as to Plaintiff and the Daoen Defendants subject only to the Daoen Defendants pending Motion to Compel 142. None of these parties has retained experts or made Rule 26(a)(2) expert disclosures so the expert discovery the Court set earlier in the case 113 is moot. The Court reviewed the parties' Status Reports 149 153. Plaintiff and Aimrock Hobbies Defendants shall file a short status report on their settlement efforts by 12/7/23. Mailed notice

REPLY by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to motion to compel 142 Compliance with Third Party Subpoena of Michael Hierl

(Exhibit A (Trent Deposition Excerpts))

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to compel Production of Documents and Award Fees and Costs Presented before Magistrate Judge

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion to compel 160 Production of Documents and Award Fees and Costs

Exhibit A (Second Amended Responses to RFPs)

Exhibit B (10-6 Alexander Letter)

Exhibit C (10-14 Doney Email)

Exhibit D (10-20 Kalbac Email)

Exhibit E (11-1 Alexander Email)

Exhibit F (11-7 Alexander Letter)

Exhibit G (2-9 Figueroa Email)

(Exhibit H (Trent Dep. Excerpts))

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court sets the following briefing schedule on the Daoen Defendants' Motion to Compel 160 : Response due by 12/4/23. Reply due by 12/11/23. Mailed notice

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Motion to Compel and for Costs, Expenses and Fees

(Exhibit A)

STATUS Report Joint Status Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

REPLY by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to Response 164 to Defendants' Motion to Compel Production of Documents and for Fees and Costs

(Exhibit A (Trent Deposition Excerpts))

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and the Parties' Stipulation of Voluntary Dismissal with Prejudice 163, any claims in the complaint against Defendant No. 76 "Aimrock Hobbies" and Defendant No. 88 "DIDI-Direct" aka "Acekeep Hobbies" and any counterclaims 77 of Defendant No. 76 and Defendant No. 88 are dismissed with prejudice. Emailed 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 12/28/2023: Mailed notice.

MEMORANDUM Opinion and Order: For all of the reasons stated in the attached Memorandum Opinion and Order, Plaintiff's Opposed Motion for a Third Extension of Time [ECF No. 131] is granted nunc pro tunc; the Daeon Defendants' Motion for Costs, Expenses, and Fees [ECF No. 69] is granted in part and denied in part; the Daeon Defendants' Itemization of Fees Being Requested in Motion for Costs, Expenses, and Fees (Dkt. #69) [ECF No. 125] is granted in part and the Court awards $6,663.60 to the Daeon Defendants; and the Daeon Defendants' Itemization of Fees Being Requested in Motion to Compel Responses to Discovery Requests and for Fees (Dkt. #99) [ECF No. 126] is granted in part and the Court awards $7,532.10 to the Daeon Defendants. Plaintiff and Plaintiff's counsel will pay Defendants Shenzhen Daeon Model Technology Co., Ltd., Shenzhen Aoxinfa Technology Co., Ltd., and Shenzhen Tianqinli Technology Co., Ltd. the total amount of $14,195.70 on or before April 10, 2024, which is 21 days from the date of this Memorandum Opinion and Order. Signed by the Honorable Jeffrey T. Gilbert on 3/21/2024. Mailed notice

MEMORANDUM Opinion and Order: For all the reasons stated in the attached Memorandum Opinion and Order, the Court denies the Daeon Defendants' Opposed Motion to Compel Compliance with Deposition Subpoena to Michael Hierl and Award Fees and Costs [ECF No. 142]. Plaintiff's motion to quash embedded in its Response brief [ECF No. 147] is denied as moot. Signed by the Honorable Jeffrey T. Gilbert on 4/1/2024. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: A telephone status hearing is set for 4/11/24 at 10:15 a.m. The call-in number is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

ATTORNEY Appearance for Defendants Aoxinfa-US, HobbyPark-US, TianqlUS, Counter Defendants Aoxinfa-US, HobbyPark-US, TianqlUS, Counter Claimants Aoxinfa-US, Aoxinfa-US, HobbyPark-US, HobbyPark-US, TianqlUS, TianqlUS by Brian Patrick Doney

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 4/11/24 and continued to 5/15/24 at 9:30 a.m. At the parties' agreement, Plaintiff will update its settlement proposal by 4/25/24, with a copy delivered to the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. The Daoen Defendants shall respond 5/9/24, with a copy delivered to the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. Both sides confirmed they still want a decision on the Daoen Defendants' Motion to Compel 160. The Court will either rule on that Motion via the CM/ECF system or set the motion for hearing and ruling. The call-in number for the continued hearing on 5/15/24 is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to Tender its Settlement Proposal [DKT. NO. 173] Presented before District Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiffs' Unopposed Motion for a First Extension of Time to Tender its Settlement Proposal 174 is granted. Plaintiff will update its settlement proposal by 4/29/24, with a copy delivered to the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. The Daoen Defendants shall respond by 5/13/24, with a copy delivered to the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. The telephone status hearing set for 5/15/24 at 9:30 a.m. is stricken and reset to 5/22/24 at 9:30 a.m. to allow the parties time to discuss the settlement letters with their clients and each other. The call-in number for the continued hearing on 5/22/24 is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MOTION by Attorney Brian P. Doney to withdraw as attorney for Aoxinfa-US, Aoxinfa-US, Aoxinfa-US, HobbyPark-US, HobbyPark-US, HobbyPark-US, TianqlUS, TianqlUS, TianqlUS. No party information provided Presented before District Judge

MINUTE entry before the Honorable LaShonda A. Hunt: Attorney Brian P. Doney's motion to withdraw 176 is granted. Attorney Doney is terminated as counsel for Defendants Aoxinfa-US, HobbyPark-US, and TianqlUS. For future reference, counsel for all parties are reminded that all motions must be accompanied by a notice of presentment in accordance with Judge Hunt's case management procedures. Non-compliant motions may be stricken. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 5/22/24. Based on the discussion held on the record and the parties' recent exchange of settlement letters, it does not appear this case realistically is in a settlement posture. If Plaintiff wants to respond to Defendants' latest settlement offer in their letter of 5/13/24, it should do with a copy delivered to the Court at Settlement_Correspondence_Gilbert@ilnd.uscourts.gov. If the parties believe the case would benefit from a settlement conference with the Court, they can send an email to the Court's courtroom deputy. Otherwise, the Court understands the parties need a decision on a pending motion to compel and Defendants may seek summary judgment on one aspect of the case. Mailed notice

MEMORANDUM Opinion and Order: For all the reasons stated in the attached Memorandum Opinion and Order, the Court grants in part and denies in part Defendants Shenzhen Daeon Model Technology Co., Ltd., Shenzhen Aoxinfa Technology Co., Ltd., and Shenzhen Tianqinli Technology Co., Ltd. Opposed Motion to Compel Production of Documents and Award Fees and Costs [ECF No. 160]. The Court grants in part the Daeon Defendants' motion to compel production of Plaintiff's settlement agreements with other defendants in this litigation that contain licensing or royalty terms related to the asserted trademarks with the redaction of all other provisions in those agreements other than as necessary for the Daoen Defendants to understand the royalty terms. The Court denies the Daeon Defendants' motion to compel production of any other settlement agreements and licensing agreements. The Court grants the Daeon Defendants' motion to compel any portions of the Excel spreadsheet referenced in the email attached as Exhibit A to Plaintiff's Response [ECF No. 164-1] related to the Daeon Defendants, and any response from Amazon to the email attached as Exhibit G to the Motion [ECF No. 161-7]) in Plaintiff's possession, custody or control. The Court grants in part the Daeon Defendants' motion to compel production of documents related to New Alchemy, but limited to agreements between Plaintiff and New Alchemy, and communications between Plaintiff and New Alchemy related to New Alchemy's investigation of the Daoen Defendants for the instant litigation, including in weekly and monthly reports to Plaintiff. The Court denies the Daeon Defendants' request for their reasonable attorneys' fees and expenses related to bringing this Motion. Signed by the Honorable Jeffrey T. Gilbert on 6/25/2024. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court denies Defendants Aoxinfa-US, HobbyPark-US, TianqlUS motion to seal 151 Exhibit B 150 to the Status Report 149 as moot. The same document that was filed under seal at 150 was also publicly filed, without objection from Plaintiff, as Exhibit A to the Memorandum in Support of Daeon Defendants' Opposed Motion to Compel Production of Documents and Award Fees and Costs [161-1]. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: The parties shall file an updated status report by 7/17/24. Mailed notice

STATUS Report Joint Status Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court has reviewed the parties' joint status report 182. A telephone status hearing is set for 7/31/24 at 10:00 a.m. The call-in number is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Emailed notice

MOTION by Defendants HobbyPark-US, Aoxinfa-US, TianqlUS for partial summary judgment Presented before District Judge

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to seal exhibits A-3 and A-4 to memorandum in support of motion for partial summary judgment Presented before District Judge

MEMORANDUM by Aoxinfa-US, HobbyPark-US, TianqlUS in support of motion for partial summary judgment 184

Declaration of Andrew Alexander

Exhibit A-1

Exhibit A-2

Exhibit A-3 (Filed under seal)

Exhibit A-4 (Filed under seal)

Exhibit A-5

Exhibit A-6

Exhibit A-7

(Exhibit A-8)

DOCUMENT REMOVED pursuant to Minute Order 192. Modified on 7/29/2024.

RULE 56.1 Statement by Aoxinfa-US, HobbyPark-US, TianqlUS regarding motion for partial summary judgment 184 Statement of Material Facts

MINUTE entry before the Honorable LaShonda A. Hunt: Defendants' motion for partial summary judgment 184 is stricken, as the motion was not accompanied by the required notice of presentment and was filed without leave of court. Defendants' Motion to Seal 185, which also was not accompanied by the required notice of presentment, is terminated as moot. The sealed document 187 will be unsealed in seven days if Defendants take no further action to withdraw it. Once all matters before Judge Gilbert are concluded and the referral is terminated, this Court will schedule a pretrial hearing to discuss next steps in the case, i.e., a firm dispositive motion schedule and/or trial date. Emailed notice.

MOTION by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to withdraw sealed document 187 (unopposed) Presented before District Judge

NOTICE of Motion by Steven P. Mandell for presentment of motion to withdraw 190 before Honorable LaShonda A. Hunt on 7/31/2024 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Defendants' Unopposed Motion for Withdraw Sealed Document (DKT. 187) 190 is granted. The sealed document filed at 187 is withdrawn. No appearance is necessary on 7/31/24. Emailed notice.

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 7/31/24. Plaintiff intends to produce additional documents by 8/7/24. The parties shall file an updated joint status report by 8/12/24 that addresses whether document production pursuant to the Court's Order 179 issued on 6/25/24 is complete so the case can be returned to the assigned District Judge for summary judgment practice and/or trial. The parties shall include in their next status report an indication of whether settlement is a realistic possibility. The Court understands the parties have discussed settlement many times in the past to no avail, and the parties reported today that settlement does not appear to be a realistic possibility at this time. The Court just wants to confirm that remains the case before terminating the referral. Mailed notice

STATUS Report Joint Status Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court reviewed the parties' Joint Status Report 194. Per the parties' suggestion, they shall file an updated joint status report by 8/19/24. Mailed notice

STATUS Report by Aoxinfa-US, HobbyPark-US, TianqlUS Presented before Magistrate Judge Modified on 11/18/2024.

(Exhibit A (Email Correspondence))

STATUS Report by Bigfoot 4x4, Inc. Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: The Court has reviewed the parties' respective Status Reports 196 197 concerning the production of Plaintiff's agreement with New Alchemy with redactions. Plaintiff shall respond to Defendant's argument as to why the financial terms of the agreement may be relevant to a claim or defense in this case and proportional to the needs of the case, and provide support for its argument that the financial terms are covered by the attorney client privilege, by 8/30/24. Defendants shall respond to Plaintiff's filing by 9/11/24. Hearing set for 9/24/24 at 10:30 a.m. in courtroom 1386. Plaintiff's counsel shall appear in person as should Defendants' local counsel. Defendants' out of town counsel may appear by telephone with 48 hours advance notice to the Court's courtroom deputy. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Memorandum in Support of Plaintiff's Discovery Production [Dkt. No. 198] Presented before District Judge

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a First Extension of Time to File a Memorandum in Support of Plaintiff's Discovery Production [Dkt. No. 198] Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Unopposed Motion for a First Extension of Time to File a Memorandum in Support of Plaintiff's Discovery Production 200 is granted. Plaintiff shall file its Memorandum in Support of Plaintiff's Discovery Production by 9/6/24. Defendant's response shall be filed by 9/18/24. Plaintiff's Unopposed Motion for a First Extension of Time 199 is stricken as duplicative. Mailed notice

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Unopposed Motion for a Second Extension of Time to File a Memorandum in Support of Plaintiff's Discovery Production [Dkt. No. 198] Presented before Magistrate Judge

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Unopposed Motion for a Second Extension of Time to File a Memorandum in Support of Plaintiff's Discovery Production 202 is granted. Plaintiff shall file its Memorandum in Support of Plaintiff's Discovery Production by 9/13/24. Defendant's response shall be filed by 9/25/24. The motion hearing set for 9/24/24 is stricken with no appearance required. The Court either will rule via the CM/ECF system or set a rescheduled hearing. Mailed notice

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendants' Request to Produce Unredacted Agreement for Services (Refer to Magistrate Judge)

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file Plaintiff's Opposed Motion for Leave to File the Declaration of Anna K. Reiter Presented before Magistrate Judge

(Exhibit A)

REPLY by Defendants Aoxinfa-US, HobbyPark-US, TianqlUS to Response 204 of Plaintiff to Defendants' Request to Produce Unredacted Agreement for Services

MINUTE entry before the Honorable Jeffrey T. Gilbert: Plaintiff's Opposed Motion for Leave to File the Declaration of Anna K. Reiter 205 is granted. Mailed notice

MEMORANDUM Opinion and Order: For the reasons stated in the attached Memorandum Opinion and Order, the Daeon Defendants' request in its Status Report and subsequent brief in support of that request, see (ECF Nos. 196, 206), to compel production of the unredacted Agreement between Plaintiff and New Alchemy is granted. Plaintiff shall produce the Agreement within seven (7) days of the date of this Order. Plaintiff can produce the unredacted Agreement subject to the Agreed Protective Order previously entered in this case. (ECF No. 119). A telephone status hearing is set for 12/3/24 at 9:30 a.m. The call-in number for the hearing is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number and security code. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Signed by the Honorable Jeffrey T. Gilbert on 11/18/2024. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 12/3/24. Plaintiff's counsel appeared. Defense counsel did not appear. Plaintiff reported that the unredacted Agreement between Plaintiff and New Alchemy was sent to opposing counsel on 11/26/24. Plaintiff also reported that it increased its settlement offer in response to Defendants' demand but has not heard back from defense counsel. A continued telephone status hearing is set 12/9/24 at 9:45 a.m. to determine whether settlement is a realistic possibly in this case. If not, the referral will be terminated, and the case will be returned to the District Juge for further proceedings. If the parties know that settlement is not a realistic possibility before the next hearing, counsel may jointly email the Court's courtroom deputy and the hearing will be stricken. The call-in number for the next hearing is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number and security code. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 12/9/24. The parties report they have agreed on the monetary terms of a settlement but are still discussing non-monetary terms. A continued telephone status hearing is set for 1/14/25 at 9:30 a.m. If there is no need for the status hearing, counsel may contact the Court's courtroom deputy, and the hearing will be stricken. The call-in number for the next status hearing is 650-479-3207 and the access code is 180 946 2499#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. 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 Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MINUTE entry before the Honorable Jeffrey T. Gilbert: Telephone status hearing held on 1/14/25. Defense counsel appeared at the start of the hearing and confirmed that the parties resolved the case, but Defendant has been waiting for a draft settlement agreement from Plaintiff for over a month. Plaintiff's counsel joined the hearing as it was concluding (he had technical problems joining earlier) and reported that he has been delayed in sending a draft settlement agreement to Defendant because Plaintiff's business shut down for the month of December for the holidays, so it has been difficult to comminate with them. The parties are still working out one last term of their settlement but report they are optimistic they will resolve that issue and be able to execute a settlement that will dispose of this case. As discovery is closed and the parties are in the process of resolving the case, the Court is of the view that the referral can be terminated as all matters relating to the referral have been addressed. If the parties cannot resolve the case, the next steps are summary judgment practice and/or trial. Both parties agree that the referral does not need to remain open under these circumstances. Referral terminated. Mailed notice

MINUTE entry before the Honorable LaShonda A. Hunt: In light of Judge Gilbert's order 212 terminating the referral because the parties have settled this case, any stipulation of dismissal shall be filed by 2/7/25. Otherwise, the case will be dismissed without prejudice with leave to reinstate within 60 days, at which point the dismissal will automatically convert to one with prejudice without further order of the court. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: The parties failed to file a stipulation of dismissal by 2/7/25, as previously ordered 213. Accordingly, this case is dismissed without prejudice and with leave to reinstate by 4/14/25. If no such motion is filed by that date, the case shall be deemed dismissed with prejudice without further order of the Court. Mailed notice (gel,)

STIPULATION Stipulation of Voluntary Dismissal

MINUTE entry before the Honorable LaShonda A. Hunt: After the parties indicated that this action had been resolved, this case was dismissed without prejudice on 2/12/25, with automatic conversion to dismissal with prejudice if no motion to reinstate was filed by 4/14/25 214. On 4/14/25, Plaintiff and Defendant No. 77 "Aoxinfa-US", Defendant No. 99 "HobbyPark-US", and Defendant No. 119 "TianqlUS" filed a stipulation of voluntary dismissal with prejudice 215. Accordingly, pursuant to Federal Rule of Civil Procedure 41(a)(1) and the stipulation of voluntary dismissal 215, dismissal of this action is converted to with prejudice as to Defendant No. 77 "Aoxinfa-US", Defendant No. 99 "HobbyPark-US", and Defendant No. 119 "TianqlUS". Upon review of the docket, the Court notes that there is one remaining defendant, Defendant No. 154 "VASTSEE", which appeared on 4/20/23 94 and obtained an extension of time to answer to 5/25/23 98 but never filed an answer. Furthermore, the docket does not reflect any subsequent activity by Plaintiff with respect to Defendant No. 154 "VASTSEE", so it appears that both sides have abandoned the case as to Defendant No. 154 "VASTSEE". Accordingly, this action remains dismissed without prejudice as to Defendant No. 154 "VASTSEE" based on such abandonment. If, by 4/25/25, nothing further is filed with respect to Defendant No. 154 "VASTSEE", then the case shall be deemed dismissed with prejudice without further order of the Court. Mailed notice (gel,)