2023-cv-00465

COMPLAINT filed by Lucia Heffernan; Filing fee $ 402, receipt number AILNDC-20280878.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SCHEDULE A by Plaintiff Lucia Heffernan Schedule A to Complaint (1) Modified on 3/1/2023.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Yanling Jiang

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Yi Bu

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Adam Grodman

ATTORNEY Appearance for Plaintiff Lucia Heffernan by Cameron Eugene Mcintyre

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MOTION by Plaintiff Lucia Heffernan for leave to file under seal

MOTION by Plaintiff Lucia Heffernan for leave to file excess pages

MEMORANDUM in support of 11 Exparte motion Modified on 1/26/2023.

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Lucia Heffernan

(Exhibit 1, of Lucia Heffernan' declaration)

EXHIBIT by Plaintiff Lucia Heffernan Sealed Exhibit 2, Declaration of Lucia Heffernan regarding memorandum in support of motion, 12 Modified on 3/1/2023.

Exhibit 2-1

(Exhibit 2-2)

presentment for 11 Exparte Motion NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 9, motion for leave to file excess pages 10 before Honorable Manish S. Shah on 2/1/2023 at 09:45 AM.

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion for a temporary restraining order, asset restraint, expedited discovery, and electronic service of process, motion for excess pages, and motion to seal 9 10 11 are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits as to the defendants listed in Schedule A, the harm to plaintiff is irreparable, and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property and causes consumer confusion. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunction. Enter Sealed TRO. Notices mailed.

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 1/31/2023. Notices mailed. Modified on 3/1/2023.

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

SURETY BOND in the amount of $ 50,000.00 posted by Lucia Heffernan (Document not scanned).

MOTION by Plaintiff Lucia Heffernan for extension of time for Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time 19 before Honorable Manish S. Shah on 2/14/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 19 is granted, and no appearance is necessary on 2/14/23. The TRO is extended to 2/28/23. Notices mailed.

MOTION by Plaintiff Lucia Heffernan for preliminary injunction

MEMORANDUM by Lucia Heffernan in support of motion for preliminary injunction 22

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 22 before Honorable Manish S. Shah on 2/21/2023 at 09:45 AM.

SUMMONS Returned Executed by Lucia Heffernan as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/15/2023, answer due 3/8/2023.

(Declaration of Service)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for preliminary injunction 22 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 2/22/2023. Notices mailed.

NEW PARTIES: DUSIbdus, Anokiss US, New More One, TSXCQM, heFeichaileiwangluokejiyouxiangongsi, Xi Xi Sign Store, Atc Win Store, MCZZFDM, mafengjun, ZHANGLINGMWJHSHOP, Start Art, chongqingyihaoyixinxijishuyouxiangongsi, kgif4fjfhd, Lucky88888, Yuhuajingshengyanjiujingxiaochu1, still yes, bchd2dfghn, xiazengyangkeji, haikousunkangshunkejiyouxiangongsi, mengchengxiansijunshangmaoyouxiangongsi1, nanninghexiangmaoyiyouxiangongsi, Chris Art, sss566, kejiahiht, A John Store, hezeweixiafuzhuangyouxiangongsi, ipiewaifenghuaifuzhuangyouxiango, TangXinShop, YSOHQ, wutiansong, zhoujianming, liangjinman, P03.ksjflkads, Plushtey, chenjinbinhaibaohuihua, LWHyishu, yanningusa, chenqinghaibao, FGREGRT7GFJTYKUK, Meecaa, Aukosy, YaXuanWangLuoKeJiYouXianGongSi, Beautiful&sister, zhoukoubeihengshangmaoyouxiangongsi, ZKQYDD, MaiYiYi, ZKMING, hanjiming-US, henanhuangangwangluokejiyouxiangongsi and hengxoo added to case caption.

NEW PARTIES: PRETTY SUN, JinDa-Shang, xingtaishihanrishangmaoyouxiangongsi, teephei, JIN Yi, LucGold, haikouzheqiwenhuachuanmeiyouxiangongsi, lifuyouasdfasdf, LiuYangShiSanShaDianZiShangMaoYouXianGongSi, lucky5858, CSM ART, nanninghongjiamaoyiyouxiangongsi, zhaotianyudexiaomaibu, TiempoG Store, Gubiyu Art, Basnake, chenjian1123, yuandaojingdedian, P04.RASOJICK, Mukagi, zhoucongshangwuyouxianzerengongsi, QJ Ecology, Fun Cloud Metal Sign, Asome sign US, WenShaoShangMaoYouXianGongSi, WANGPENGGONGSI, xinshaoxiandongbingbaihuodian, weishao54, Jiaoheshibaixingneiyidian, putianshilichengquxiangmieyumaoyiyouxiangongsi, Citzhiie(US Shipping), StarPoster, FANSHENGXIONG, wulixing666, Ideal Appeal, Aenaon shop, lijinyourt, DONGDAOVUONGSTORE, chenxibaihuodian123, FDY MY, moxiaa, shaheshishilitingbaobaoyichutongzhuangmenshi, xingtaimengtingshangmaoyouxaingongsi, retjui, hhlzcy, xingtainuotingshangmaoyouxiangongsi, YTJETYJETYJETYJ and haikourususongda added to case caption.

NEW PARTIES: wujuweidexiaodian, THRTHHFGNDTHRT, xiangduqushoukuandianzichanpinjingyingbu, tercc, poxety, xingtaiyaroushangmaoyouxiangongsi, Shengyitong store, lushanxianzhuoyunmaoyiyouxiangongsi, MOJIU, haikoulingwudianzishangwuyouxiangongsi, LJJ Shop, Jackie Sign, jiangyongming50447, Eva Callister, CBeckNic, DonRodney, LIUSJ Store, fghdtyu, Fu Lai ba, PTYD Wall art painting, Yovccuwmwveziming, ltiuerhyqiuwd, AAQQZ55, Vieccistop, MyraJud, Humberto Faria Gutirrez, CEleanor, Deidra Owenss, Panadera la Molina, Stephanie Santerre, Sebasti5, Geoffro, Glenda Whitee, GaryMon, AmeliaF, y dlkajsdlkas, Sheryl Cranford, Rudy Escobarg, TINA L GARZA, Christopher James Chatigny, Discover material, Mildreds, Jonathan Gannon, shichengzhuo Store, Kexiangying, wangshuling1, humengxue24192, xuke1234, zhangchunqiao Store and surprise yu added to case caption.

NEW PARTIES: YIJIN27, zhaobingqing9642786, panchenyu7513, luoxidong11210, Ghgfdxb, qucaiyu45678, vcdfre33, wutingting6705, surprise yue, Pafiwmq52a, yuguijing Store, YIJIN47, YIJIN48, caichenxin389568, gaozhiyuan7890, YIJIN059, langworthjenni185, wanghaiyu1234, surprise 55, pangxiangyang85219, lilishaung55642, weimeiyue6688, liukaijie5566, YIJIN034, wangwenchao84592, DSS665, surprise ming, zhaoxinglin1998, Muyiebybi Shoes, chenchuhuan4305, paynyahy, liuerfeng6952, lijinrui Store, wangjiaxin12323, caoxupeng6426, haungxiaoqiong Store, YIJIN11, wwx001, canyadengpin and huanglin Store added to case caption.

MOTION by Plaintiff Lucia Heffernan for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Lucia Heffernan in support of motion for default judgment 28

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 28 before Honorable Manish S. Shah on 3/21/2023 at 09:45 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] Defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held on 3/21/23. For the reasons stated in open court, the motion for default judgment 28 is granted. Enter Default Judgment. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 3/21/2023. Notices mailed.

SATISFACTION of Judgment as to defendant no.79 xinshaoxiandongbingbaihuodian