2023-cv-01700

COMPLAINT filed by Zinkia Entertainment; Filing fee $ 402, receipt number AILNDC-20454702.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED DOCUMENT by Plaintiff Zinkia Entertainment Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Zinkia Entertainment by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Zinkia Entertainment by Yanling Jiang

ATTORNEY Appearance for Plaintiff Zinkia Entertainment by Yi Bu

ATTORNEY Appearance for Plaintiff Zinkia Entertainment by Adam Grodman

ATTORNEY Appearance for Plaintiff Zinkia Entertainment by Cameron Eugene Mcintyre

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Zinkia Entertainment

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 Zinkia Entertainment for leave to file under seal

MOTION by Plaintiff Zinkia Entertainment for leave to file excess pages

MEMORANDUM in support of [12] Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Alberto Delgado Gavela

Exhibit 1, of Alberto Delgado Gavela's declaration

Exhibit 2, of Alberto Delgado Gavela's declaration

SEALED EXHIBIT by Plaintiff Zinkia Entertainment Sealed Exhibit 3, Declaration of Alberto Delgado Gavela regarding memorandum in support of motion, [13]

presentment for Exparte Motion [12] and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages[11], motion for leave to file[10] before Honorable Charles P. Kocoras on 3/23/2023 at 09:30 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA (jk2,)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal [10] is granted. Plaintiff's motion to exceed page limitation [11] is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, expedited discovery and service of process by email and/or electronic publication [12] is granted. Motion hearing set for 3/23/2023 is stricken. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Charles P. Kocoras on 3/22/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 10,000 posted by Zinkia Entertainment (Document not scanned) (jk2,)

MOTION by Plaintiff Zinkia Entertainment for extension of time for temporary restraining order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time 20 before Honorable Charles P. Kocoras on 4/6/2023 at 09:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion to Extend the Temporary Restraining Order [20] is granted. Motion hearing set for 4/6/2023 is stricken. Mailed notice

MOTION by Plaintiff Zinkia Entertainment for preliminary injunction

MEMORANDUM by Zinkia Entertainment in support of motion for preliminary injunction[23]

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[23] before Honorable Charles P. Kocoras on 4/11/2023 at 09:30 AM.

SUMMONS Returned Executed by Zinkia Entertainment as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/3/2023, answer due 4/24/2023.

Declaration of Service

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Preliminary Injunction 23 is granted. Motion hearing set for 4/11/23 is stricken. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Charles P. Kocoras on 4/6/2023: Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: In light of the Preliminary Injunction entered on 4/6/2023 28, The law firm of JiangIP LLC 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

NEW PARTIES: kylebuy, ma47k_505941, matthew1963hr, mishel22, ranas_6743, vabot_5083, weishuangsuo, yuedaguojimaoyiyouxiangongsi, Hidodo (Tianjin) Electronic Commerce, Yiweisai (Shenzhen) Electronic, A dendrobium, ADVSRFGVBSD3SFBDFGBDNBFGN, anxinliuxinxizixunyouxiango, big jack us, chichenghonglan, chixiangdianshop, Choicenjoy, cishangxinjialixia, Cnwjesws, DaHuaUS, DU CHUAN, fanwenlong store, fenxudianzikeji, ffcheer, HAHAzzzz, HanHaoWangYangQingZheng, HanSongHS001, he nan feng yang wang luo ke ji you xian gong si, H-EASY, hezeyanhuiwangluokejiyouxiangongsi1503, huyongliangdedianpu, JIANFA2022, JIAYANGSHANGMAO, jinanjinzhishenghuidianzishangmaoyouxiangongsi1, JinWuJianCaiYouXi, KMKYL LCC, LC-SHOP, liangqizhucedebeimeidianpu, lijinhuadebeimeidianpu, lixiangjundedian, LUZHOUJINGPINDIAN, Mao Lan Shang Mao, MengHuaiTeShuDianZi, Mengj, MILE-Direct storefront, oLxcougan, pengfengfuzhuangfushidian, PengJianDHSKJHFKJDSJKD and POKY Backdrop added to case caption. (Text entry; no document attached.)

NEW PARTIES: Qingzhoushibadeshangmaoyouxiangongsi, Qingzhoushiruizishangmaoyouxiangongsi, QiuRenDongDSHLDJKSHJHJXHX, RAAKH, RElala, shijingjingde, shuifujiaoqushangmaoyouxiangongsi, TANGHUUSA, TAOTAO Boutique, TattoosKids, TIANBMBD, tongbaixianchenkaishangmaoyouxiangongsi, US BIG WORLD, USHAIWEI, VUVUTITAO Store, WEILANLAN, wenluoqiyeyongzejd, woshierbi yyds, Xiamen Xinchengbin Network Technology Co., Ltd., Xiangchengshiaolafushangmaoyouxiangongsi, xingchengyusi, XINXINHUI, xuhaihongg, xxgzs, XxxxTenDn, yanggangde, YangXiangDongErJia, yangxiaoleii, yanxunhangeyozhidianzi, yibobaihuodian, Yichunranyaodianzishangwuyouxiangongsi, ymxhezhijian shop, yonzhen, yotishangmao, YRYL, yuduntaishangmao, yuehaijie1, yunchengshimalushangmaoyouxiangongsi, Yunhai Department Store, Yunhui, YZJXBH7 to 15 days for delivery, zhaolinzhi, ZHENGzhengrishang, zhinenggou, Ziyoko US and Beautiful Mind Co.,Ltd added to case caption. (Text entry; no document attached.)

NEW PARTIES: Daiyi, Elecsop, Everything You Need, Fox, Grocery Shop, hangzhoushuanghongbaozhuangyouxiangongsi, Hope Star, JQ CO.Ltd, Lamuusaa, LianQU Ltd, Liyucwill, LuckiStars.LLC, MMY Store, OMKARSY, shenzhen jier maoyi youxiangongsi, shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshibaipinyouyimaoyiyouxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi, shenzhenshimeihuidawangluokejiyouxiangongsi, UTI STORE and XIANNINGYUANZHANDIANZISHANGWUYOUXIANGONGSI added to case caption. (Text entry; no document attached.)

NEW PARTIES: Nguyn vn danh added to case caption. (Text entry; no document attached.)

NEW PARTIES: xiao and -YikN- added to case caption. (Text entry; no document attached.)

(Bu, Yi) (Text entry; no document attached.)

NEW PARTIES: ' added to case caption. (Text entry; no document attached.)

(Bu, Yi) (Entered: 04/18/2023) (Text entry; no document attached.)

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

MEMORANDUM by Zinkia Entertainment in support of motion for default judgment[30]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[30] before Honorable Charles P. Kocoras on 5/2/2023 at 09:30 AM.

ATTORNEY Appearance for Defendants Daiyi, JQ CO.Ltd, Lamuusaa, MMY Store, shenzhen jier maoyi youxiangongsi, shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi, shenzhenshimeihuidawangluokejiyouxiangongsi by Michael Thomas Stanley

MOTION by Defendants Daiyi, JQ CO.Ltd, Lamuusaa, MMY Store, shenzhen jier maoyi youxiangongsi, shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi, shenzhenshimeihuidawangluokejiyouxiangongsi for extension of time to file answer regarding complaint 1 Agreed

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file answer, 34 before Honorable Charles P. Kocoras on 5/4/2023 at 09:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Motion hearing set for 5/2/2023 regarding Plaintiff's Motion for entry of Default and Default Judgment 30 is stricken. Court will rule by mail. Defendants' agreed motion for extension of time to respond to the complaint by 5/17/2023 34 is granted. Motion hearing set for 5/4/2023 is stricken. Mailed notice

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

DEFAULT JUDGMENT ORDER. Signed by the Honorable Charles P. Kocoras on 5/3/2023. Plaintiff's Motion for entry of Default and Default Judgment against the Defendants identified in First Amended Schedule A 30 is granted. Mailed notice

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

MOTION by Defendants Daiyi, JQ CO.Ltd, Lamuusaa, MMY Store, shenzhen jier maoyi youxiangongsi, shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi, shenzhenshimeihuidawangluokejiyouxiangongsi for extension of time to file answer regarding complaint[1]

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file answer, [40] before Honorable Charles P. Kocoras on 6/8/2023 at 09:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants' Second Motion for Extension of Time to Respond to the Complaint through and including 6/28/2023 40 is granted. Motion hearing set for 6/8/2023 is stricken. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 17 Choicenjoy

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

MOTION by Attorney MIchael Stanley to withdraw as attorney for shenzhenshilongyuanyishedianzishangwuyouxiangongsi. New address information: shenzhenshilongyuanyishedianzishangwuyouxiangongsi, longgangqu bantianjiedao bantianshequ, liyuanxincun108hao706,shenzhen,guangdong,518129,CN

NOTICE of Motion by Michael Thomas Stanley for presentment of motion to withdraw as attorney, 45 before Honorable Charles P. Kocoras on 8/31/2023 at 09:30 AM.

MOTION by Plaintiff Zinkia Entertainment for leave to file under seal

Motion by Zinkia Entertainment to Oppose 45

Exhibit 1, filed under seal

Exhibit 2, filed under seal

Exhibit 3, filed under seal

Exhibit 4, filed under seal

Exhibit 5, filed under seal

(Exhibit 6, filed under seal)

SEALED EXHIBIT by Plaintiff Zinkia Entertainment regarding other, 48

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

(Exhibit 6)

MOTION by Plaintiff Zinkia Entertainment for leave to file under seal

MOTION by Plaintiff Zinkia Entertainment for order to show cause

Exhibit 1, filed under seal

(Exhibit 2, filed under seal)

SEALED EXHIBIT by Plaintiff Zinkia Entertainment regarding MOTION by Plaintiff Zinkia Entertainment for order to show cause 51

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Charles P. Kocoras: Unopposed motion to withdraw as counsel 45 is granted. Attorney Michael Thomas Stanley no longer represents defendant, shenzhenshilongyuanyishedianzishangwuyouxiangongsi.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion(s) for leave to file under seal [47, 50] is granted.

MINUTE entry before the Honorable Charles P. Kocoras:The Court has received electronic notification of Plaintiff's motion to oppose [45] as well as plaintiff's motion for order to show cause [51]. A telephonic status hearing is set for 9/7/2023 at 10:20 a.m. Attorney Michael Thomas Stanley is directed to personally appear for the telephonic status hearing on 09/07/2023. Plaintiff's counsel shall serve a copy of this order to attorney Michael Thomas Stanley. For the telephonic status hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking.

MINUTE entry before the Honorable Charles P. Kocoras: Telephone status hearing held and continued to 10/10/23 at 10:10 a.m. Plaintiff's motion to oppose 48, is granted. The order granting attorney Michael Thomas Stanley motion to withdraw 53 is vacated for the reasons stated on the record. The motion for order to show cause 51 is continued. The parties are directed to meet and confer consistent with the Court's directives as stated in open court. Joint submission is due by 9/28/23. For the telephonic status hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Telephone Conference set for 10/10/2023 at10:10 AM.Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 120 shenzhen jier maoyi youxiangongsi

MINUTE entry before the Honorable Charles P. Kocoras:On the Court's own motion, the 10/10/23 telephonic status hearing is stricken and reset for 10/19/2023 at 10:20 a.m. For the telephonic status hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking.

MOTION by Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi for extension of time to file Unopposed Motion for Extension of Time to File Joint Submission Pursuant to Court Order D.E. 56

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file, 59 before Honorable Charles P. Kocoras on 10/5/2023 at 10:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras:Defendants' unopposed motion for extension of time to file joint submission pursuant to Court Order D.E. 56 59 is granted. Defendants' shall file the joint submission on or before 10/19/23. The 10/05/23 notice of motion and the 10/19/23 status hearing are stricken. The Court will set a future hearing date after the joint submission is filed.

TRANSCRIPT OF PROCEEDINGS held on September 7, 2023 before the Honorable Charles P. Kocoras. Order Number: 46916. Court Reporter Contact Information: Ms. Joene Hanhardt, Official Court Reporter, 219 S. Dearborn Street, Suite 1744-A, Chicago, Illinois 60604, 312-435-6874. 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 10/26/2023. Redacted Transcript Deadline set for 11/6/2023. Release of Transcript Restriction set for 1/3/2024.

MOTION by Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi for extension of time to file Unopposed Motion for Extension of Time to File Joint Submission Pursuant to Court Order D.E. 61

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file, [63] before Honorable Charles P. Kocoras on 10/24/2023 at 10:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants' unopposed motion for extension of time 63 is granted. Defendants shall file the joint submission by 11/9/2023. Motion hearing set for 10/24/2023 is stricken. The Court will set a future hearing date after the joint submission is filed. Mailed notice.

MOTION by Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi for extension of time Unopposed Motion for Extension of Time to File Joint Submission Pursuant to Court Order D.E. 65

NOTICE of Motion by Michael Thomas Stanley for presentment of extension of time, 66 before Honorable Charles P. Kocoras on 11/14/2023 at 10:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras:Defendants' shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi unopposed motion for extension of time to file joint submission pursuant to Court Order D.E. 65 66 is granted. The joint submission shall be filed by 11/30/23.

ATTORNEY Appearance for Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi by Larry Ford Banister, II (Def. Nos. 121 & 123)

MOTION by Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi to set a briefing schedule as to Plaintiff's Motions D.E. 45 and 51

MOTION by Defendants shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi for reconsideration regarding order on motion for leave to file, text entry[54] Reconsider Order Granting Motions to File Under Seal

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for reconsideration, [71], motion by filer to set a briefing schedule[70] before Honorable Charles P. Kocoras on 12/5/2023 at 10:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants' motions [70, 71] are taken under advisement. The 12/05/23 notice of motion date is stricken. The Court will issue a ruling by mail.

MINUTE entry before the Honorable Charles P. Kocoras: This matter is hereby referred to the Magistrate Judge for discovery supervision, including conducting any proceedings necessary to resolve the Motion to Show Cause [51], Motion for Reconsideration [71], and Motion for Briefing Schedule [70], and the issues identified therein. The Magistrate Judge has full authority to set and modify deadlines.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Beth W. Jantz for the purpose of holding proceedings related to: discovery motions: motion to set a briefing schedule [70], motion for reconsideration, [71], motion for order to show cause [51] and discovery supervision with authority to set and modify deadlines.

MINUTE entry before the Honorable Beth W. Jantz: This case has been referred to this Court to rule on the pending discovery motions in this case [[51], [70], [71]]. The Court has reviewed the filings and transcripts in this case. The Court notes that Judge Kocoras ordered a joint submission regarding the relevant bank account at the hearing on 9/7/23. [Dkt. [62] at 7:11-14.] Despite several extensions [[61], [65], [68]], the parties did not file that submission on 11/30/23 as ordered. The Court hereby orders the parties to submit that joint submission for this Court's review on or before 12/14/23. If the parties miss this deadline again, the Court will be requiring an in person status appearance of all counsel of record in the case. The Court takes the pending motions under advisement until the Court reviews the parties' joint submission. Mailed notice.

MEMORANDUM set deadlines, [76] by shenzhenshi shenghuashuo dianzishangwu youxiangongsi, shenzhenshilongyuanyishedianzishangwuyouxiangongsi Joint Statement

MINUTE entry before the Honorable Beth W. Jantz: The Court has reviewed the parties' joint status report [77]. Plaintiff and Defendant report that Plaintiff tendered a settlement demand to Defendant on 12/13/23. Plaintiff has requested an additional 30 days to attempt to settle the case before moving forward with any of the pending motions or discovery. The Court believes that would a prudent course of action at this time. A telephonic status is set for 1/18/24 at 10:00 a.m. Central. If the parties are unable to settle this matter ahead of this date, the Court will set additional deadlines during the status hearing, and all counsel of record will be required to call in. To join the 1/18/2024 status conference by phone, dial 888-273-3658 and enter access code 2217918. Members of the public and media will be able to call in to listen to this hearing. 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. The status hearing will be cancelled and no one need call in if a stipulation to dismiss is filed with the District Judge prior to the hearing. Mailed notice.

MOTION by Plaintiff Zinkia Entertainment to approve consent judgment Presented before District Judge, MOTION by Plaintiff Zinkia Entertainment for permanent injunction Presented before District Judge

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's Motion for Entry of Consent Final Judgment and Permanent Injunction as to Defendants 79 is granted. All pending motions [51, 70, 71] are terminated as moot and all pending deadlines and hearings in this case are hereby stricken. The referral in this case to the magistrate judge is closed. Enter Consent Judgment. Civil case terminated.

CONSENT JUDGMENT Signed by the Honorable Charles P. Kocoras on 12/20/2023.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 121 shenzhenshi shenghuashuo dianzishangwu youxiangongsi and no. 123 shenzhenshilongyuanyishedianzishangwuyouxiangongsi