2023-cv-01497

COMPLAINT filed by Nike, Inc.; Filing fee $ 402, receipt number AILNDC-20427506.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Nike, Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Nike, Inc. for leave to file under seal

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by Nike, Inc.

ATTORNEY Appearance for Plaintiff Nike, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Nike, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Nike, Inc. by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff Nike, Inc. by Marcella Deshonda Slay

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.)

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (Text entry; no document attached.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Nike, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Nike, Inc. in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Joe Pallett regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-23 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

Exhibit 3-10

Exhibit 3-11

Exhibit 3-12

Exhibit 3-13

Exhibit 3-14

Exhibit 3-15

Exhibit 3-16

Exhibit 3-17

Exhibit 3-18

Exhibit 3-19

Exhibit 3-20

Exhibit 3-21

Exhibit 3-22

(Exhibit 3-23)

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

MEMORANDUM by Nike, Inc. in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal 3 is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery 13 is granted. Plaintiff's motion for electronic service of process pursuant to FED.R.CIV.P.4(f)(3) 18 is granted. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Charles P. Kocoras on 3/24/2023. Mailed notice

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

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

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

MEMORANDUM by Nike, Inc. in support of extension of time[25]

Declaration of Jake M. Christensen

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order 25 is granted. The TRO is extended until 4/21/23. Mailed notice

MOTION by Defendant nfreery to dismiss complaint, MOTION by Defendant nfreery Dissolve Restraining Order. (Exhibits)

MINUTE entry before the Honorable Charles P. Kocoras: Motion to Dismiss Plaintiff's Complaint and Dissolve Restraining Order 28 is entered and briefed: Response due by 5/3/2023; Reply is due by 5/17/2023. Court will rule by mail. Mailed notice

MOTION by Plaintiff Nike, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[30]

Declaration of Jake M. Christensen

Exhibit 1

MOTION by Plaintiff Nike, Inc. for sanctions Pursuant to Rule 37

Exhibit A

DECLARATION of Jake M. Christensen regarding motion for sanctions[32]

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/18/2023, answer due 5/9/2023.

Declaration of Marcella D. Slay

Exhibit A

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for entry of a preliminary injunction 30 is granted. Plaintiff's motion for sanctions pursuant to Rule 37 32 is granted. The law firm of Greer, Burns & Crain, Ltd. is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website located at www.ilnd.uscourts.gov/instructions. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Charles P. Kocoras on 4/20/2023. Mailed notice

NEW PARTIES: A2L1R1CKG9Q4ID, A2O3R48TY8Z3Z8, Angellin, anime for you, anqinglianggeyewangluokejiyouxi, anqingyuanyuanshangmaoyouxiangongsi6828, Asunyu, BAIRIXIN, chaiyongqiang01, CHANA TECH, chengdujinzhilishangmaoyouxiangongsi, chengdushuzhicaiji, ChinFun Online, chixincheng-bm, cixianzhangcongbaihuodian, Coagram-US, DANZHOUAOLIANDIANZISHANGWUYOUXIANGONGSI, donghanhua, Efrain Diaz, elicoocool, EPINWAY, Fashion Sports US, fengliangliangsadferfdf, figfolydgbe, Flashherokids, FLYWORLDIRECT, galagala-US, gongqinwang, GuPing-Hats, HaoBBD, HEISHIDIANNAOYOUXIANGONGSI, HOT-SHOES-Ltd, houyupeng, JFLLAGO, JiaNiu, JiuJiangHuangYunYang, JiuJiangMaShaoCong, Joniehouse, Jooniehuse, JunShang Pavilion, Kelout, kunmingliuhaiduimingshangmaoyouxian, LaRiau, late-Last, lijilijinhuanhuadamaiyouxiangongsi, lisai111, liuxiaolongyouxiangiongsi, LROLATR, Luaky, LXYR-US, mapeilong2, MaQi2, mawenxiangdebeimeidianpu, Neonawall, nfreery, NiFENG-CAPS, NKLANYARD, Odema, Ohlookhere, Ovxvxm, oyumaoyiyouxiangongsi, POS DERICT, qujingliujindianzishangwuyouxiangongsi, Rnks, SBGC-US, ShanYuFangZhi, ShaoYuHaO, shenmidongfangyouxuan, sijihuacheng, silu qingsi, sjcm1104, SmallSuper, Sport Hats, Sports accessories Store, Spyoungrollers, STRDR, Stxiefushangdian, terenwan6, TianQiaoHuShiZhen, TOTGO US, wangshoucaikeji, WAYCWG, weihongwangluokejiyouxiangongsi, WEKORYC, Wlijhgytvb, WOO_STORE, XaviyPerkin, XCAEVGEQWBVEW, XIANGLONGDIANNAOYOUXIANGONGSI, Xunmingflashmall, XXFuture-US, yktyetyee, YUN Store 8-15 Days Arrival, yunxiaoxianwushanbaihuodian, yunxiaoxianzixuebaihuodian, YXkj, YYYD OFFICIAL, ZENG JIE HUI, zengduquwenxiangxubaihuodian, ZhangLianLian, ZhuWenChen, cc2shoes Store, fashio_nluxury_shoes Store, running_shopping Store, running_sport Store, sneakerstore001 Store, sneakerstore550 Store, tandou Store, tina520_1314 Store, Wholesalejdsneaker Store, ajwsw5_43, blueberbestmall, bluelans7, breezeye, coolhair88, flavorstore, freetime1915, fuzh92, givetry2020, hanaor57, hongchuan999, huddoshop, mcsl_wtrade, peey46, tianfang518, trading_happy_garden, yesgo2020, yuansha13, zedonxi0, zhangchen_56, zylns8899, TTMouldSupplies, Romaytic, Pandimagic, Shaobing Huang, Ting Shoes, benjamin88866, boom1950_official, chaolongc, chen_nic8, chin.a7800, china_shoes1125, china_sportshoes, cindy_onfootsneaker, connolly.luca, derek002_shoes, dongxia.chen.52, frankyang0817, freidajavon, herbert95888, huangruoling01, jennysport888, kabin0789, kers_og_hh, kobynike12, leifengsports, lingling_supplier, mo0714.shoe, monicasneaker.cc, mr._chens_shoes, ni.tuo.940, nicejordansnet3, nike.adidas888, rogeda0001, ryannorman4, sh.oes8642, shaoqing2891, shoes.nikesb, shoeslover008, shoesupplier3, sneakerjordan_vip, sneakshoes2022, susansnkrs6, tylllme, uncle.eddi3s, vj_forward, wengkk750, woniufashion, xuemiao6, y867306094, ydd11422, z15366440588, asdoklhq, bolaiyao Accessories Beauty Co. ltd, Caihui and Ciaoed life Co. ltd added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In light of the Notice of Voluntary Dismissal 38 filed on 5/3/23, Defendant nfreery's motion to dismiss and to dissolve restraining order 28 is denied as moot. Mailed notice

MOTION by Defendant tylllme for more definite statement.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Nike, Inc. as to Certain Defendants

MOTION by Plaintiff Nike, Inc. for entry of default as to Certain Defendants, MOTION by Plaintiff Nike, Inc. for default judgment as to Certain Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment 44

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

ATTORNEY Appearance for Defendants Caihui, sjcm1104 by Adam Edward Urbanczyk

MOTION by Defendants Caihui, sjcm1104 for extension of time

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Caihui and sjcm1104's motion for extension of time [48] is granted. Defendants Caihui and sjcm1104 shall answer the complaint or otherwise plead by 6/2/23. Mailed notice

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

ATTORNEY Appearance for Defendant STRDR by Brian Swift

MOTION by Plaintiff Nike, Inc. for Sanctions Pursuant to Rule 37

Declaration of Jake M. Christensen

Exhibit 1

MOTION by Defendant STRDR for extension of time to file answer

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for entry of Default Judgment against all remaining Defendants, with the exception of defendant TYLLME [44] is granted. Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: Motion for More Definite Statement [41] is entered and briefed as follows: Response is due by 6/2/2023; Reply is due by 6/9/2023. Court will rule by mail. Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Sanctions Pursuant to Rule 37 [52] is granted. Motion for extension of time to respond to Plaintiff's Complaint on or before 6/12/2023 [53] is granted. Mailed notice

MOTION by Plaintiff Nike, Inc. for entry of default as to Defendant tylllme, MOTION by Plaintiff Nike, Inc. for default judgment as to Defendant tylllme

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[57]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[58]

Exhibit 1

LETTER from TYLLME dated 05/26/2023.

LETTER from TYLLME dated 05/26/2023.

LETTER from TYLLME dated 05/28/2023.

LETTER from TYLLME dated 05/28/2023.

MINUTE entry before the Honorable Charles P. Kocoras: Order entered on 5/24/23 [56] is amended to include the following: Defendant tylllme's motion for more definite statement [41] is stricken. Mailed notice

LETTER from Yan Wencan dated 5/30/23.

RESPONSE by Plaintiff Nike, Inc. to letter[62], letter[63], letter[61] to Defendant Tylllme's letter Motion for Reconsideration and Reply in Response to Defendant's Opposition

Declaration of Jake M. Christensen

Exhibit 1

Exhibit 2

FINAL JUDGMENT ORDER. Signed by the Honorable Charles P. Kocoras on 6/1/2023. Plaintiff's motion for entry of default and default judgment against defendant tyllme (Def. No. 179) [57] is granted. Mailed notice

MOTION by Defendant Caihui for extension of time

MINUTE entry before the Honorable Charles P. Kocoras: Defendant Caihui's motion for extension of time [68] is granted. Caihui shall answer the complaint or otherwise plead by 6/23/23. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Charles P. Kocoras on 6/8/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order[70] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[70] in the amount of $500,000 as to certain defendant

NOTICE of Voluntary Dismissal by Nike, Inc. as to Certain Defendants

MOTION by Plaintiff Nike, Inc. for entry of default as to Defendant sjcm1104, MOTION by Plaintiff Nike, Inc. for default judgment as to Defendant sjcm1104

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[74]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[75]

Exhibit 1

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Entry of Default and Default Judgment Against Defendant SJCM1104 74 is granted. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Charles P. Kocoras on 7/20/2023: Mailed notice

FULL SATISFACTION of Judgment regarding order 78 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 70 in the amount of $500,000 as to certain defendant

GENERAL ORDER 23-0040: EXECUTIVE COMMITTEE ORDER: IT APPEARING THAT, the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable Jeffrey I. Cummings; therefore IT IS HEREBY ORDERED that the attached list of 290 cases be reassigned to the Honorable Jeffrey I. Cummings; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable Jeffrey I. Cummings' webpage on the Court's website for the purpose of reviewing instructions regarding scheduling and case management procedures; and IT IS FURTHER ORDERED that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new district judge for twelve months from the date of this Order; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Jeffrey I. Cummings to the Court's civil case assignment system during the next business day, so that he shall receive a full share of such cases; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Jeffrey I. Cummings to the Court's criminal case assignment system ninety (90) days so that Judge Cummings shall thereafter receive a full share of such cases. Case reassigned to the Honorable Jeffrey I Cummings for all further proceedings. Honorable Charles P. Kocoras no longer assigned to the case. Signed by Honorable Rebecca R. Pallmeyer on 10/26/2023.

ORDER : STANDING ORDER REGARDING REASSIGNED CIVIL CASES: This case has been re-assigned to the initial calendar of Judge Jeffrey I. Cummings. All previously set status and motion hearing dates are stricken. All previously set discovery deadlines and briefing schedules remain intact. Signed by the Honorable Jeffrey I Cummings on 10/30/2023: Mailed notice.

STATUS Report per 82 by Nike, Inc.

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiff's status report 83, which indicates that all non-defaulted remaining defendants have since been voluntarily dismissed. Civil case terminated.

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiff's status report 83, which indicates that all non-defaulted remaining defendants have since been voluntarily dismissed. Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order 70 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 70 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 70 in the amount of $500,000 as to certain defendants