2022-cv-07253

COMPLAINT (Redacted) filed by John Doe; Filing fee $ 402, receipt number AILNDC-20174210.

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SEALED EXHIBIT by Plaintiff John Doe Exhibit 1 regarding complaint[1]

SEALED EXHIBIT by Plaintiff John Doe Schedule A regarding complaint[1]

SEALED DOCUMENT by Plaintiff John Doe Complaint

CIVIL Cover Sheet

SEALED DOCUMENT by Plaintiff John Doe Notice of Trademark Claims

ATTORNEY Appearance for Plaintiff John Doe by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff John Doe by Sameeul Haque

MOTION by Plaintiff John Doe for Leave to File Certain Documents Under Seal and Temporarily Proceed Under a Pseudonym

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment.

MEMORANDUM by John Doe in support of motion for miscellaneous relief[9]

Declaration of Martin F. Trainor

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MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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.

SEALED MOTION by Plaintiff John Doe for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

SEALED DOCUMENT by Plaintiff John Doe Memorandum in Support of Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

SEALED DOCUMENT by Plaintiff John Doe Declaration of Paul Varley

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(Exhibit 2-13)

MOTION by Plaintiff John Doe for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by John Doe in support of motion for miscellaneous relief[16]

Declaration of Martin F. Trainor

Exhibit 1

Exhibit 2

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MEMORANDUM by John Doe Establishing that Joinder is Proper

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for leave to file certain documents under seal and temporarily proceed under a pseudonym [9], ex parte motion for a temporary restraining order [13], and motion for service by publication and electronic service [16]. Provided that Plaintiff provides the security described in paragraph 10 of the temporary restraining order, the temporary restraining order shall become effective on January 11, 2023 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 1/6/2023. Emailed notice

SURETY BOND in the amount of $ 10,000 posted by John Doe. (Document not Scanned)

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

MOTION by Plaintiff John Doe to Extend the Temporary Restraining Order

MEMORANDUM by John Doe in support of motion for miscellaneous relief[22]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order [22]. Enter Temporary Restraining Order Extension Order. The Temporary Restraining Order [20] shall now expire on 2/8/2023 at 6:00 p.m. Emailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 1/23/2023. Emailed notice

NOTICE of Voluntary Dismissal by John Doe as to a certain Defendant

NEW PARTIES: Chisato Mori added to case caption. Terminating John Doe

ATTORNEY Appearance for Plaintiff Chisato Mori by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Chisato Mori by Sameeul Haque

MOTION by Plaintiff Chisato Mori to Extend the Temporary Restraining Order as to Certain Defendants

MEMORANDUM by Chisato Mori in support of motion for miscellaneous relief[29]

Declaration of Martin F. Trainor

MOTION by Plaintiff Chisato Mori for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Chisato Mori in support of motion for preliminary injunction[31]

Declaration of Sameeul Haque

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's motion to extend the temporary restraining order as to certain Defendants [29]. The temporary restraining order [20] has already been extended by a period of 14 days [25]. Plaintiff has not argued that Defendants 1 through117 have consented to this extension. The case law cited to by Plaintiff in its motion supports the denial of this requested relief, and the Court declines to extend the temporary restraining order beyond the 28-day period, and denies the motion with prejudice. H-D Michigan, LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 844 (7th Cir. 2012) ("In our view, the language of Rule 65(b)(2) and the great weight of authority support the view that 28 days is the outer limit for a TRO without the consent of the enjoined party, regardless of whether the TRO was issued with or without notice.") Emailed notice

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's motion for an entry of a preliminary injunction as to certain Defendants [31]. The Court has reviewed the docket in this case and Plaintiff has not filed any Summons Returned for the Defendants 118 through 241. The Court enters and continues this motion for decision until the Summons Returned has been filed with the Court. Emailed notice

SUMMONS Returned Executed by Chisato Mori as to The Partnerships and Unincorporated Associations Identified On Schedule A on 2/7/2023, answer due 2/28/2023.

Declaration of Sameeul Haque

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SUMMONS Returned Executed by Chisato Mori as to The Partnerships and Unincorporated Associations Identified On Schedule A on 2/9/2023, answer due 3/2/2023.

Declaration of Sameeul Haque

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MOTION by Plaintiff Chisato Mori for preliminary injunction as to certain Defendants

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MEMORANDUM by Chisato Mori in support of motion for preliminary injunction[37] as to certain Defendants

Declaration of Sameeul Haque

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, and based on the information and exhibits included in Plaintiff's summons returned for all named Defendants [35] [36], Plaintiff's motions for an entry of a preliminary injunction [31] [37] are granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: the Complaint [4], including Exhibit 1 and Schedule A [2]-[3], Plaintiff's Motion for Entry of a Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery [13] and accompanying supporting memorandum, declaration, and exhibits, including screenshot printouts showing the Defendants' infringement of Plaintiff's Trademark [14]-[15], Plaintiff's Notice of Claims Involving Trademarks [6], and the TRO [20] are unsealed. TME Law, P.C. is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instruction can be found in the attachment to this entry. Emailed notice

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 2/13/2023. Emailed notice

NEW PARTIES: Anhui Ximeng International Trade Co., Ltd., Baoding Baigou Xincheng Lerong Xiaowo Plush Toy Factory, Dongguan Orui Toys & Gifts Co., Ltd., Hebei Yerong Trading Company Ltd., Nanning Maggie Trading Co., Ltd., Shenzhen Dahoufa Technology Co., Ltd., Shenzhen Levin Toys & Gifts Co., Limited, Shenzhen Yingyan Trading Co., Ltd., Yangzhou Caisheng Handicraft Product Co., Ltd., Yangzhou Stech Toys Co., Ltd, Yangzhou White Beard Toys Co., Ltd., Yiwu Chenfei Toys Co., Ltd., Yiwu Hao Kun Trading Firm, Yiwu Kaixixiang E-Commerce Firm, Yiwu Misha Toys Co., Ltd., Babytoys (drop shipping) Store, Healing Decor Crystals Store, Hoocid Store, Raccoon kigurumi Store, Shop1100237025 Store, toysuppler, 2021=Support Drop Shipping Store, A_A Scarecrow Store, About Car Store, Ali Children's Toy Store, Aliso Store, Anime Peripheral Toys Store, Astart-plush toy Store, Atina Store, Baby board game(drop shipping) Store Store, Baby's Fantasic World Store, Beautifulmate Store, bellala Store, BlueCool Store, BOOKFONG Official Store, buildingblocks Store, Changjiang Store, Chase Lee Store, Child Toys Store, Children's Funny Store, Clman Store, CN Cosplay Store, CosAnimal, DaiDai Plush Toys Store, Dayday e shop Store, DotBoutique Store, DUDU Plush Toys Store, E-DROPSHIPPING STORE, Far away 18 Store, Fashion Lucky Jewelry Store, Fit Stones Store, Giselle toys Store, Good-Dropshipping Store, GSF DL Plush Store, GSF LHB Plush Store, Jatektoon Official Store, juege09Store Store, jun jun Store, June F Toy Store, JY Baby Store, Kigurumi Unicorn Official Store, KK Smart Toy Store, Ladybug Store, Li-zi Plush toys Store, LuckyLucky Store, ManyFun Store, Mathileon Factory Store, Matoo Store, Mattll Store, MUZI Boutique Store, OK Toy Drop Shipping Store, pajamasea Official Store, Prettyplus+ Store, Rabbtoy Store, RC 1979 Store, Roblox Store, SHELL FISH Official Store, ShierToySale Store, Shop1100043145 Store, Shop1102056617 Store, Shop1102158823 Store, Shop1102204114 Store, Shop1102262346 Store, Shop1102263125 Store, Shop1102265353 Store, Shop1102270092 Store, Shop1102272046 Store, Shop1113240 Store, Shop3214013 Store, Shop342746 Store, Shop5259060 Store, Shop5368326 Store, Shop7758258 Store Store, Shop911057089 Store, Shop911606176 Store, Shop911761646 Store, STYLISH WIZ Store, Support Drop Shipping 555 Store, Support Drop Shipping 666 Store, Support Drop Shipping 888 Store, Surprise plushtoy Store, TONGKWOK Official Store, TooTtoys Store, Toy Funny World Store, TreasuringU Store, Trendy Cartoon Plush Toy Store, TuMube Store, Very Beautiful Toy Store, Very Good Toy Store, We All Need Toy Store, Whitebeard' Store, XH168 Store, XianMing Store, XIAO-Support Drop Shipping Store, Xuanxuan's Store, XZCAI Exclusive Store, Yuduobao Toy Store, Ahanblaim, Changsha Liuyang Huaimiao Electronic Commerce Co., Changsha Ziyuming Electronic Commerce Co., Ltd., chibiluxubaihuodian, Fashion Society Direct, Good quality goods, guangzhoufabaomaoyiyouxiangongsisdsad, Havertz Sports, LOLODAY, NNVDMJ, Smiling Angel, wanzaiblankets, Yongshengzhijia.store, Zi-only, zuchenggheng, ai789, ai795, aiyue2020, anfuhaiyi, asd0786, b1zi, baofu007, bei10, bestfucheng, bkpl, blingblingyy, boyuancase, cftgff, cuel, cukojew, daisysan, dou08, Ekvz, elnl, fashionaccessory1, fgit, fierysethy, fredericay, fzctl2, fzyiyi, gbnb, gigi695, hai05, huhu6, hxas, ipxx, iqb5, jeiy, jitc, jiu08, juju66, kangsitech, keiv, kokig, kuo07, Kvaq, kvt1, LJ fashion, lkjiu01, logcct97tt, lowr, lto4, lwkdo, make03, make08, mfcd, New Hot Jewelry, Newkeygood, nickyoung06, nomt, npkh, nqcj, nxystyle, ooow, pcycinternational, Phkfuzecheng04, Powerstore07, Pu09, putiannikeon1, pyihai2021, quan07, qywz, r0hh, ryananderson, s29x, sdwe88, sdwe889, sellerstore08, shangguanxin, shen84, shmily2019, sihuai06, sportlight_company, squishies, summm_wholesale, sungua55, taa0, tlc_watches, tmall2012, Toy wholesales Store, tozg, umxt, v4dl, velocity_777, warren07, wmgb, xiaorouchuan, xing08, xzxzccc, yambags, youyiu3, zinf, Zubv, PlasticandyShop, WQHoodie, Ecomland, Shenzhen Bluelans Networks Techology, BellaFun, DaviKnight, G Palelei, Blakking, Yangzhou Dulala Crafts Ltd. and Diana Accessories added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A

NOTICE of Voluntary Dismissal by Chisato Mori as to certain Defendants

NOTICE of Voluntary Dismissal by Chisato Mori as to certain Defendants

NOTICE of Voluntary Dismissal by Chisato Mori as to certain Defendants

NOTICE of Voluntary Dismissal by Chisato Mori as to certain Defendants

MOTION by Plaintiff Chisato Mori for entry of default, MOTION by Plaintiff Chisato Mori for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Chisato Mori in support of motion for entry of default, motion for default judgment[45]

Exhibit 1

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[46]

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment [45]. Pursuant to 15 U.S.C. § 1117(c), Plaintiffs are awarded statutory damages from each of the Defaulting Defendants in the amount of two hundred thousand dollars ($200,000.00) for willful use of counterfeit Plaintiffs' Trademarks in connection with the sale of products through at least Defaulting Defendants' Online Marketplaces. This damages award is a reasonable balance between providing some measure of compensation and deterrence, without crossing the line into over-deterrence. The two hundred thousand dollar ($200,000.00) award shall apply to each distinct Defaulting Defendant only once, even if they are listed under multiple different aliases in Schedule A. Enter Final Judgment Order. The ten thousand dollar ($10,000.00) surety bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Plaintiff or his counsel, TME Law, P.C. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Martin Francis Trainor of TME Law, P.C., 3339 S. Union Avenue, Chicago, IL 60616 via certified mail. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 4/5/2023. Emailed notice

MAILED out the ten thousand dollars ($10,000) surety bond posted by Plaintiff to Martin Francis Trainer of TME Law P.C. via Certified Mail Receipt Article Number: 7021 1970 0001 3330 0403.

MAILED out the ten thousand dollars ($10,000) surety bond posted by Plaintiff to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. via Certified Mail Receipt Article Number: 7021 1970 0001 3330 0410.

NOTICE of Correction regarding mailed out entry.

FULL SATISFACTION of Judgment as to certain Defendants

FULL SATISFACTION of Judgment as to certain Defendants

FULL SATISFACTION of Judgment as to a certain defendant