2023-cv-01858

COMPLAINT filed by Lululemon Athletica Canada Inc.; Filing fee $ 402, receipt number AILNDC-20475220.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Lululemon Athletica Canada Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lululemon Athletica Canada Inc.

Notice of Claims Involving Trademarks by Lululemon Athletica Canada Inc.

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Thomas Joseph Juettner

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Susan E. Cox. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

(List of Trademarks Ex. 1)

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

MOTION by Plaintiff Lululemon Athletica Canada Inc. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Lululemon Athletica Canada 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 Jenny Vo regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 1 - 10 regarding declaration 16

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

Exhibit 4-6

Exhibit 4-7

Exhibit 4-8

Exhibit 4-9

(Exhibit 4-10)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 11 - 20 regarding declaration 16

Exhibit 4-11

Exhibit 4-12

Exhibit 4-13

Exhibit 4-14

Exhibit 4-15

Exhibit 4-16

Exhibit 4-17

Exhibit 4-18

Exhibit 4-19

(Exhibit 4-20)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 21-25 regarding declaration 16

Exhibit 4-21

Exhibit 4-22

Exhibit 4-23

Exhibit 4-24

(Exhibit 4-25)

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

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 13, motion for miscellaneous relief 20, motion for leave to file 3 before Honorable Elaine E. Bucklo on 3/31/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal [3]; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, temporary transfer of the domain names, a temporary asset restraint and expedited discovery [13]; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [20] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 4/14/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/7/2023. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 5/15/2023 at 9:45 a.m. (to track the case only, no appearance is required). By 5/8/2023 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

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

SEALED TEMPORARY Restraining Order Signed by the Honorable Elaine E. Bucklo on 3/31/2023. Mailed notice

SURETY BOND in the amount of $ 10,000 posted by Lululemon Athletica Canada Inc. (Document not imaged.)

MOTION by Plaintiff Lululemon Athletica Canada Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Lululemon Athletica Canada Inc. in support of extension of time 26

(Declaration of Kahlia R. Halpern)

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 26 before Honorable Elaine E. Bucklo on 4/12/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 26 is granted to 4/28/2023. Mailed notice.

MOTION by Plaintiff Lululemon Athletica Canada Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for preliminary injunction[31]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[31] before Honorable Elaine E. Bucklo on 4/28/2023 at 09:45 AM.

SUMMONS Returned Executed by Lululemon Athletica Canada Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/25/2023, answer due 5/16/2023.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction 31 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint 2, Exhibit 4 to the Declaration of Jenny Vo 17, 18, 19, and the TRO 25. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 4/28/2023. Mailed notice.

NEW PARTIES: Benyue Sport Store, BY Sport Store, FITNESSLULU Store, LULU Fitness Sports Store, LULU NICE BAGS Store, Shop1102195982 Store, Shop1102268226 Store, aning95 Store, fashion_seller Store, luluyogatwo Store, nancysupplier Store, Smartears, soccerjerseys2024 Store, victor_wong Store, yangguangone Store, 0cv153ed-jia, 1b91ep5qkx, 6fv4s8g-qiang, anth_dige, behkweoom369, caidan636, chasingdreams99, chaudhary165, chenqiang96, chuang95, chuiqi_2267, cosy.delicacy_e1ph2, ddrfmqvswx, dingq94, dyn3-3, ect570, gdfehuty665, grl-yoga-n1.o, gybeck, handmadejewelry_774, hefeizahngcixinxi-0, hezic86, hoeation92, itianfei571, jiang7906, jonas_5, kena0810, kgyu123kjh, kongfzz, langzemaoyi, lanze-8842, larissa-store75, lifengyig2hao, lirvbn, longyu-lucky99, lyffhter789, meifanzuo, meitongwaimao, naijian-84, nanningshenghuidianz0, nci756, niaopa-77, nmnbvvn, no.1-41freg8, pmrnfgtjh3367, qiequne-woqo, rankous65, rmgurxylnona9, ruian0712, runawayye, runkaimaoyi, shen952-28, shengli85, sjsi9gmlxn, slidety05, sun.yoga.a1z, suntianshijie56131, uyrtew, vgfcdfgd-0, wanghuilin00000000132, weirong-5, wengguo6859, worthhaving9, xiaomiba399, xingfumandou, xuziqiang, yanke527kou2, yanming2367, ying520, yoga.sport-vv9, yohkoh, yufeng5, zdv-79, zhangping57, zhenhu_8556, zhiya_316, Y.JW Ggstore, lemonfitnessinetwork.com, leggingsoutletstore.com, gymclothesale.com, gymleggingsclothes.com, gymleggingsshop.com, lulugymclothes.com, fitnesswearstore.com, fitness-wearss.com, lemonfitnessclothes.com, lululeathleticapparel.com, lululenonmexico.com, lemonleggingsoutletshop.com, lululemonjapan.net, lululeclothesretailers.com, missningstore.com, lululemon-jp.top, lululemonportugal.net, lululemoncanada.net, lululemononlineus.com, dupagerelo.com, rachaelwoods.com, goodsvipstore.com, outletleggingsshopy.com, outletleggingsshopus.com, auohger.shop, zolxhgu.shop, fiqshopyy.com, oadjgo.shop, lululemoncopenhagen.us, lululemonhelsinki.us and lululemonoslo.us added to case caption.

STATUS Report per 24 by Lululemon Athletica Canada Inc.

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with several defendants. Plaintiff will move for default judgment at a later date where appropriate. Status hearing is reset for 6/26/2023 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 6/20/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to Certain Defendants

MOTION by Plaintiff Lululemon Athletica Canada Inc. for entry of default, MOTION by Plaintiff Lululemon Athletica Canada Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for entry of default, motion for default judgment[41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment[41] before Honorable Elaine E. Bucklo on 5/31/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment against the defendants identified on Schedule A 41 is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Lululemon or its counsel, Greer, Burns & Crain, Ltd. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 5/31/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $250,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 46 in the amount of $250,000 as to certain defendant