2023-cv-01780

COMPLAINT filed by Bigfoot 4x4, Inc.; Jury Demand. Filing fee $ 402, receipt number AILNDC-20463896.

(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 Virginia M. Kendall. Designated as Magistrate Judge the Honorable Maria Valdez. 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 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

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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Virginia M. Kendall. Due to medical reasons, Parties shall contact the emergency duty Judge regarding presentment date for Motion for Temporary Restraining Order 10. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for leave to file under seal 6 and Motion for leave to file excess pages 9 are granted. Motion hearing set for 4/24/2023 at 9:15 AM regarding Motion 10. Virtual hearings will be held on Fridays at 9:30 AM. Virtual hearing requests must be pre-approved by the Court. If you need to appear virtually, send the attached form to Judge Kendall's courtroom deputy. The courtroom deputy will inform you as to whether your request has been approved. Mailed notice

(Virtual Hearing Request Form)

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion due to medical reasons, Motion hearing set for 4/24/2023 is stricken. Parties are directed to contact the emergency Judge to reset Motion hearing. Mailed notice

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 10 before Honorable John Robert Blakey on 4/26/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants Plaintiff's emergency, ex parte motion for entry of a temporary restraining order 10 and strikes any notice of motion date. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 5/2/23. Mailed notice

SEALED ORDER Signed by the Honorable John Robert Blakey on 4/18/2023. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 6/8/2023 at 9:15 AM. If Parties need a Status hearing prior to 6/8/2023, please contact Judge Shah's courtroom deputy. If a Motion is filed prior to 6/8/2023, please notice it before Judge Shah for a hearing. Mailed notice

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

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 26 before Honorable Manish S. Shah on 5/2/2023 at 09:45 AM.

Order on Motion for Extension of Time

MINUTE entry before the Honorable Manish S. Shah: The motion to extend the TRO 26 is granted and the ex parte TRO is extended to 5/16/23. No appearance on the motion is necessary. Notices mailed.

CIVIL BOND in the amount of $ 10,000 posted by Bigfoot 4x4, Inc. (Document not Imaged).

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

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for preliminary injunction 30

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 30

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 30 before Honorable Manish S. Shah on 5/16/2023 at 09:45 AM.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

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 5/11/2023, answer due 6/1/2023.

ATTORNEY Appearance for Defendants Moobody, Cool BUY by Mark K. Suri

ATTORNEY Appearance for Defendant Cool BUY by Mark K. Suri

ATTORNEY Appearance for Defendants Cool BUY, Moobody by Roger M Masson

RESPONSE by Cool BUY, Moobodyin Opposition to MOTION by Plaintiff Bigfoot 4x4, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction 30

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. Counsel for Defendants Cool BUY and Moobody appears in court. For the reasons stated in open court, the motion for preliminary injunction 30 is granted in part and denied in part. Defendants Cool BUY and Moobody are not subject to the preliminary injunction order. Enter Preliminary Injunction Order, modified to exclude those two defendants. 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 5/16/2023. Notices mailed.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal Without Prejudice as to Defendants No. 120, 142

NEW PARTIES: Yz Jewelry Co., Ltd., zhengqianhan Trading Co., Ltd., ZIYORK CO., LTD, city market 4, ineffable 10, jyd-nan, menhouse 1, qunyijiaju, rcrover-us, ruiwayrc, sacnade11, startabc, tang2-22, ALDSJKLJKA, Aliwnvo, dengzhoushiliuyanshangmaoyouxiangongsi, feiyigongzuoshi, Litailong, Ls-Shop, WFCYDJJ, Xianlangyubaihuojingxiaoshang, YEYEP, zhoumaohua, BX ONE, FanHang Sports equipment, JINIE LIFE, limingcheng, YangToy, YAO moon, ALET Co.Ltd, CM, CM department, D s choice Co. Ltd, Daoke Technology Co., Ltd., DEOZHE, Dian zi Accessories, DimensionPai, DOYOUNG Co.Itd, FanTingh Co. Ltd, Floleo, Fuxin Ruisi Trading Co., Ltd., GGTHE Store, Henuo Technology Co., Ltd., HLW, ji fu qin, kang ha sun, ken ji tun, Krqap, Kurqity Stores, LAIQIANKUA, Lunaipu Store, LUUSI, MianYangYaXinLiKeJiYouXianGongSi, MUSUPER Co., Ltd, Niutotem, Outdoor And Toys, Phyachelo Home Furnishing, pi zha rui, Qili Digital Technology Co., Ltd., Ruirun Maternity Co. Ltd, Sherry All, shou guai sheng, SRong Store, SSychome Co. Ltd, SZ Tools & Hardware Co.Ltd, tai yuan ou si chi dian zi shang wu you xian gong si, tai yuan yue ji xuan shang mao you xian gong si, taiyuanweichenlishangmaoyouxiangongsi, TIERPOP, TM, Tuo Yu, TYLBkk.CLEARANCE, Vntub, WA Pink, WARIGOOD Co.Ltd, xia fang piao shang mao, XINYTEC Co.Ltd, YAZHIYY Co. Ltd, Yinfan Toys Co. Ltd., ZAZA house, ZENTREE Co.Ltd, Zhenpuha Trading Co. Ltd, zhi jiang shi mu qin, Zoe Home Store, ZQ and Zun Tao Store added to case caption.

NEW PARTIES: eldara96, naor6 22, shopping what else, children club, Redddits, wuyuan, yejiamin, Aleta Co.Ltd, assorted, Bs choice Co. Ltd, BestYo Co Ltd, CENSENG Co., Ltd., Convenience Plus Store, daisoug, DOHEMER Co., Ltd., Duto store, Epoch, Furniture Co.Ltd, FYSRMAY Co., Ltd, GamyXI Co.Ltd, Gejunyong E-commerce Co., Ltd., Good Neighbor Store, good stuff store, GRANDBAY Co. Ltd, guangzhoudawohuimaoyi, guangzhoufeiyiyimaoyi, Hezhuoli Trading Co., Ltd., HIABIO Co.,Ltd, HISUNTON, HOMSINO Co., Ltd, HOMSOM Co.Ltd, HT store, Huote Plai Co.Ltd, jia luo jue, JJ Sport Co.Ltd, JS Elec Co. Ltd, Jue biyu Store, jue jiang yao, jue si fu Trading Co., Ltd., jue tu min shang mao, JUNEONCE, Lin Kong Store, Lion cub, listdy, Lonni Department Store Co. Ltd, LP Electronics Co.Ltd, LTQ Vehicle Co.Ltd, luosa, Meda Home Co.Ltd, Moon Arrow, Natazmig, Newlyfond, NingCheng Co.Ltd, NouXYang Co. Ltd, NY Electronics Co. Ltd, PAPADA, Partygee, Paxton Top, PHONIUSER, pobbo, Qiang La Jue Co. Ltd, Quan PR Co.Ltd, Ruilian Accessories Co., Ltd., Seans Boutique Shop, SHAWSEN Co. Ltd, Shi Pu Hu Gou Shang Mao Co. Ltd, shuo shuo da kang, Snowilla, Surprised zr, tai yuan ting teng kai mao shang mao you xian Co. ltd, Te tai Digital Store, TY Motor Co.Ltd, USF Tools Co.Ltd, VIRGINE, W.WOO Co. ltd, WAYHERO Co.Ltd, xi jue gu mao yi, Xiang Shenhong Store, Xiangyutai Store, Yao Minyi Store, YHAOTP, YIWANS Co., Ltd., Yootye Co.,Ltd, Yu Han Co.Ltd, Yu Heng Heng Co.Ltd, YUEWAY and YUTIPGER added to case caption.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 152

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No.110

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 6/8/2023 is reset for 9:30 AM (PLEASE NOTE TIME CHANGE). Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 6/8/2023. Plaintiff's Counsel reports they are working on resolution with remaining Defendants. Status hearing set for 7/20/2023 at 9:15 AM. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 128, 162

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

EXECUTIVE COMMITTEE ORDER: GENERAL ORDER 23-0024: IT APPEARING THAT, the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable Jeremy C. Daniel; therefore IT IS HEREBY ORDERED that the attached list of 282 cases be reassigned to the Honorable Jeremy C. Daniel; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable Jeremy C. Daniel's 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 Jeremy C. Daniel 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 Jeremy C. Daniel to the Court's criminal case assignment system twelve (12) months so that Judge Daniel shall thereafter receive a full share of such cases. Case reassigned to the Honorable Jeremy C. Daniel for all further proceedings. Honorable Virginia M. Kendall no longer assigned to the case. Signed by Honorable Rebecca R. Pallmeyer on 6/27/2023.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 144

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

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

CONSENT JUDGMENT. Signed by the Honorable Jeremy C. Daniel on 7/20/2023. Agreed motion for entry of Consent Judgment 52 is granted. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 145

DECLARATION of William B. Kalbac Declaration of Service

MOTION by Plaintiff Bigfoot 4x4, Inc. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for default judgment 57

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 57

(Exhibit Hierl Exhibit 1)

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing set for 9/28/2023 at 9:30 a.m. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 150

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Motion for entry of default and default judgment against the defendants identified on Amended Schedule A [57] is granted. Counsel shall send the proposed default judgment order to proposed_order_daniel@ilnd.uscourts.gov in Word format. Mailed notice

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 9/29/2023. Civil case terminated. Mailed notice

MOTION by Defendant Krqap to vacate default judgment.

MINUTE entry before the Honorable Jeremy C. Daniel: Defendant's motion to vacate default judgment 64 is entered and briefed as follows: plaintiff's response is due on or before 11/29/2023; any reply due on or before 12/6/2023. Status hearing set for 12/20/2023 at 9:30 a.m. in courtroom 1419. Mailed notice

RESPONSE by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Response to Defendant's Motion to Vacate Default Judgment [Dkt. No. 64]

Exhibit A

(Exhibit B)

NOTICE of MOTION by Defendant Krqap to withdraw.

MINUTE entry before the Honorable Jeremy C. Daniel: Defendant Krqap's motion to withdraw 67 is granted. Defendant Krqap's motion to vacate 64 is withdrawn. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 140