2023-cv-02213

COMPLAINT filed by Rarog j.d.o.o.; Filing fee $ 402, receipt number AILNDC-20523849.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

Schedule A by Plaintiff Rarog j.d.o.o. Schedule A to Complaint (1) Modified on 5/3/2023.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yi Bu

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Adam Grodman

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Cameron Eugene Mcintyre

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Rarog j.d.o.o.

MOTION by Plaintiff Rarog j.d.o.o. for leave to file under seal

MOTION by Plaintiff Rarog j.d.o.o. 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 Sanda Krstulovic

(Exhibit 1, of Sanda Krstulovic's declaration)

EXHIBIT by Plaintiff Rarog j.d.o.o. Sealed Exhibit 2, Declaration of Sanda Krstulovic regarding memorandum in support of motion, 13 Modified on 5/3/2023.

Exhibit 1

Exhibit 2

(Exhibit 3)

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 Elaine E. Bucklo on 4/14/2023 at 09:45 AM.

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 10 ; Plaintiff's motion to exceed page limitation 11 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery and service of process by email and/or electronic publication 12 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 4/28/2022 any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/21/2023. JiangIP LLC 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 5/30/2023 at 9:45 a.m. (to track the case only, no appearance is required). By 5/23/2023 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.

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Elaine E. Bucklo on 4/14/2023. Modified on 5/3/2023.

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

CIVIL BOND in the amount of $ 10,000 posted by Rarog j.d.o.o. (Document not Scanned).

MOTION by Plaintiff Rarog j.d.o.o. for extension of time for Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time 20 before Honorable Elaine E. Bucklo on 4/28/2023 at 09:45 AM.

MOTION by Plaintiff Rarog j.d.o.o. for preliminary injunction

MEMORANDUM by Rarog j.d.o.o. 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 Elaine E. Bucklo on 5/3/2023 at 09:45 AM.

SUMMONS Returned Executed by Rarog j.d.o.o. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/27/2023, answer due 5/18/2023.

NEW PARTIES: neimengguwangshangzhuanmaidian, Hehaoyang, Agile-Studio, tuyoushangmaote, Ruimeimei, NanChangAoSiBenMaoYiYouXianGongSi, shenpengdianzishangwu, QUFECH, anxleISt, Wirziis Fashion, ZPOKELEGG, Taghhand, Gibobby, AAru2K, eilrgd, honglenglo, Nyybw, mhifae22, Katrina's Gift, Foelsemt(7-15 Days Delivery), AUCUAO, erdiore Shops, YANIEC, XunRui, Balakie, 7-15 Days Fast Deliver Selinora, Buolo, insaneness, charmsamx, EIiuetnvyi-L, CGMDTZ, WPOUMV, Qisenshangmao, ylioge Brand Store, kbndieu, Leikf Direct, Jinelet, Memund, Aboser-, Meikosks, wehenwok, hemlock, RKSTN Fashion, Pelang, Huilaibazo Store, 7-12 Days Delivery-OIFGH, YLSDY, SILKAITER, Snowflakes-s, Sunshine-Y 7-15 Days Delivery, UTTOASFAY, Geeun, YUINBNS, Notamut and Kn iuGHs added to case caption. (Text entry; no document attached.)

NEW PARTIES: drindf, YiJiejia(7-12 DAYS), huizze, RENyi-F, Miluxas, Kokovifyves, Dresses for Women 2023 On Sale, douk-Quite, Aalonpy, Beataan 7-15 Days Delivery, Shidaile, akaocozus 7-15 Days Delivery, HamousHei_K, JASME, Mimacoo-Store, Pitauce, KA-Vfenx, SBOJTH, Visit the F_Lupery Store, BomKwow, BonLana, KLFGJ, Youpinqijiandian, Wamajoly, late-Last, shutiaocp, FORUU(7-14 Days Delivery), lanerpo, HRSTUYL, Dimplesss, Mebamook Shop, DHUNK, chiweiyings, Kexdaaf, Feledorashia, WEDA, Anjikang, Honey Peach, SHOPESSA and Save 90% Clearance Sale Qonioi Outlet Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: feer zimicui, Jovati, Muugo 7-15 Days Delivery, DPTALR, WeiQingJun, Landao Innovations, jvwted, nfreery, Yingjujia(10-20 Days Delivery Time), 2023 Summer Clothes Deals, HOXINE, WuXingShuoAnQingPoWuShang, hanguoxin1995, YDNGF, tuoMR, Demaxiye, Haiwae FAST DELIVERY, Miximx, FlekmanArt (US Warehouse), FAVIPT (7-15 days Delivery), Dreamlascar, tanzhenbo, FZYLQY, Shnmi, Mnhhatv1, bozmiai, yaobenmei, Geneh, tongshanxiandongebaihuodian, zhangkaijiedejingpinxiaodian, lisiboo, CHHCMG, shengzongyun, ddfg5d6fg46df5g465f, Givvet-us, FC-ELEC, zhaimengba, jinanmengxiwangluokejiyouxiangongsi, zhenghuilandedian, YINOVEEN Inc, Zdony, wyyeleswm, Lifepal Joy Shop, TNCDJKPA, dgzhumeng, REAXOY Official, DDB-Direct, Minoly, Fenliny-US, LZDS, DIOJDES, taodedianpu, shanxifengconganqishangmao and jiliu1150152 added to case caption. (Text entry; no document attached.)

NEW PARTIES: Mixxeed, gaozhenfeng, LANLUO, lolololol99, LIke by, qujingwangleidianzishangwuyouxiangongsi, XinchengMOYU, shishangshi, caocaocao33, suitengyundianzishangwushop, kaifuqujunyueriyongpinshop, baoshanxuanshengcaiwuguanliyouxiangongsi, putianshichengxiangquqiyuqujiajufang, bst-shop, Guangzhou Zhuoyang Trading Co., Ltd, XuZeXiang, JiuJiangAoKeManShangMaoYouXianGongSi, anqingtaozhishangmaoyouxiangongsi, zhuzhoushilingwenshangmaoyouxiangongsi123, gdadfgfgdfa, LFFZFDD, ZJGJMY, qujinglankuodianzishangwuyouxiangongsi, Anytrsum, IndepenD, NUFOMO012 Store, Weiforestsen(ship from USA), CraftPinsShop, XPOLYM, lixindebeimeidianpu, pmayu87, lixinxianmingchengmaoyiyouxiangongsivb, Chfukew Bathroom supplies, yangyanjunyhx and BoomDerhe added to case caption. (Text entry; no document attached.)

NEW PARTIES: Exte 6-12 days Fast Delivery and K&KP added to case caption. (Text entry; no document attached.)

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

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

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

(Declaration of Service, Keith A. Vogt)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion to extend temporary restraining order for good cause 20 is granted to 5/12/2023. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction 22 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Plaintiff's Schedule A to the Complaint(s) 2, Exhibit to the Declaration of Sanda Krstulovi 14, and the TRO 18. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 5/1/2023. Mailed notice.

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

MOTION by Plaintiff Rarog j.d.o.o. for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Rarog j.d.o.o. 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 Elaine E. Bucklo on 5/25/2023 at 09:45 AM.

ATTORNEY Appearance for Defendants HRSTUYL, Mebamook Shop, QUFECH, TNCDJKPA by Adam Edward Urbanczyk

MOTION by Defendants HRSTUYL, Mebamook Shop, QUFECH, TNCDJKPA for extension of time

ATTORNEY Appearance for Defendants Katrina's Gift, insaneness by Adam Edward Urbanczyk

STATUS Report Pursuant to [17] by Rarog j.d.o.o.

MOTION by Defendants Katrina's Gift, insaneness for extension of time

ATTORNEY Appearance for Defendant XuZeXiang by Yong Chen

MOTION by Defendant XuZeXiang for extension of time to file answer regarding complaint[1] UNOPPOSED

ATTORNEY Appearance for Defendant Foelsemt(7-15 Days Delivery) by Michael Thomas Stanley

MOTION by Defendant Foelsemt(7-15 Days Delivery) for extension of time to file answer regarding complaint[1] Unopposed

ATTORNEY Appearance for Defendants Beataan 7-15 Days Delivery, BomKwow, BonLana, Foelsemt(7-15 Days Delivery), Gibobby, Jinelet, Memund, Notamut, Shidaile, Taghhand, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok by Michael Thomas Stanley

MOTION by Defendants Beataan 7-15 Days Delivery, BomKwow, BonLana, Foelsemt(7-15 Days Delivery), Gibobby, Jinelet, Memund, Notamut, Shidaile, Taghhand, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok for extension of time to file answer regarding complaint[1]

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

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the status report. Plaintiff's motion for entry of default and default judgment against the defendants identified in first amended Schedule A [30] is granted. Enter Default Judgment Order. Defendants motion for extension of time [34], [37], [39], [41], and [43] are granted. Defendants response(s) to Plaintiff's Complaint are due by 6/12/2023.Status hearing is reset for 7/13/2023 at 9:45 a.m. as to non-dismissed defendant. (to track the case only, no appearance is required). The parties shall file a joint status report by 7/6/2023 and the court will enter an appropriate order. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 5/25/2023. Mailed notice.

AMENDED DEFAULT JUDGMENT Order signed by the Honorable Elaine E. Bucklo on 5/26/2023. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 88 late-Last

MOTION by Defendants Beataan 7-15 Days Delivery, BomKwow, BonLana, Foelsemt(7-15 Days Delivery), Gibobby, Jinelet, Memund, Notamut, Shidaile, Taghhand, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok for extension of time to file answer regarding complaint[1] Second Agreed Motion to Extend

MOTION by Defendants Katrina's Gift, insaneness for extension of time UNOPPOSED

MINUTE entry before the Honorable Elaine E. Bucklo: Parties to take note of Judge Bucklo's motion call practice posted on her page at www.ilnd.uscourts.gov. Defendant's second agreed motion for extension of time to respond to the complaint [49] and Defendants' unopposed motion for extension of time [50] is granted to 7/3/2023. Mailed notice.

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

STATUS Report Joint Status Report by Rarog j.d.o.o.

MOTION by Defendants Beataan 7-15 Days Delivery, BomKwow, BonLana, Foelsemt(7-15 Days Delivery), Gibobby, Jinelet, Memund, Notamut, Shidaile, Taghhand, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok for extension of time to file answer regarding complaint[1] Third Agreed Motion for Extension

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file answer, [54] before Honorable Elaine E. Bucklo on 7/13/2023 at 10:15 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 28 7-15 Days Fast Deliver Selinora

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the parties' joint initial status report. Defendants' third agreed motion for extension of time to respond to the complaint [54] is granted to 7/17/2023. This case is referred to Magistrate Judge McShain for a settlement conference. Status hearing is reset for 8/28/2023 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 8/21/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Heather K. McShain for the purpose of holding proceedings related to: Settlement Conference. Mailed notice.

MINUTE entry before the Honorable Heather K. McShain: This case has been referred to Magistrate Judge McShain to conduct a settlement conference [58]. A telephone conference with the Court is scheduled for 07/28/2023 at 9:30 a.m. to discuss the parties' interest in settlement and, if appropriate, set a schedule for the exchange of settlement proposals and a date for the settlement conference. Counsel primarily responsible for representing the parties must participate in this conference call, and counsel should come prepared to discuss the availability of counsel and decisionmakers in August, September, and October. The Court will also address logistics for the settlement conference itself, which will take place remotely. In advance of the telephone conference, counsel are directed to review Magistrate Judge McShain's Standing Order for Settlement Conferences (available on the Court's website at www.ilnd.uscourts.gov by selecting the link for Magistrate Judge McShain and then the link for "Settlement Conferences"). To participate in the telephone conference, the dial-in number is 888-684-8852, followed by access code 8623687#. 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. Mailed notice.

MINUTE entry before the Honorable Heather K. McShain: Telephone conference held on 07/28/2023. There are three defendants remaining who are in active settlement negotiations with plaintiff, and the parties request more time to continue those settlement negotiations on their own before committing to a settlement conference. Another telephone conference is set for 08/30/2023 at 9:00 a.m., at which time the parties will update on the status of their settlement negotiations and whether they wish to pursue a settlement conference with the Magistrate Judge. To the extent the parties wish to schedule a settlement conference, they should come prepared with availability of both attorneys and decisionmakers in September and October. Counsel should utilize the same dial-in information [59] for the telephone conference on 08/30/2023. Mailed notice.

MOTION by Defendants Beataan 7-15 Days Delivery, BomKwow, BonLana, Foelsemt(7-15 Days Delivery), Gibobby, Jinelet, Memund, Notamut, Shidaile, Taghhand, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok for extension of time to file answer regarding complaint[1] Fourth Motion to Extend Presented before District Judge

NOTICE of Motion by Michael Thomas Stanley for presentment of motion for extension of time to file answer, [61] before Honorable Elaine E. Bucklo on 8/4/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants' fourth motion for extension of time to respond to the complaint [61] is granted to 8/14/2023. Pending settlement conference before Magistrate Judge McShain, Status hearing is reset for 9/7/2023 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 8/31/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

SATISFACTION of Judgment as to [Certain] defendants

MINUTE entry before the Honorable Heather K. McShain: Telephone conference held on 08/30/2023, and continued to 09/14/2023 at 8:30 a.m. By the next telephone conference, the Court expects that defense counsel will have an update as to status of settlement regarding defendants 43, 74, and 83 and that defense counsel will have filed a motion to withdraw as to defendants 11, 39, 40, and 75 so that plaintiff may proceed with its next steps in the litigation as to those four defendants. To participate in the telephone conference on 09/14/2023, the dial-in number is 888-684-8852, followed by access code 8623687#. 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. Mailed notice.

STATUS Report Joint Status Report by Rarog j.d.o.o. Presented before District Judge

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report in which plaintiff represents that settlement discussions are proceeding with certain defendants and that plaintiff will move for default judgment at a later date where appropriate. Pending the telephone conference before Magistrate Judge McShain, status hearing is reset for 10/12/2023 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 10/5/2023. The court will enter a scheduling order in response to the status report.Mailed notice.

MOTION by Attorney MIchael Stanley to withdraw as attorney for BomKwow, Jinelet, Memund, Shidaile, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok. New address information: Contact information provided within brief Presented before Magistrate Judge

CERTIFICATE of Service by Michael Thomas Stanley on behalf of BomKwow, Jinelet, Memund, Shidaile, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok regarding MOTION by Attorney MIchael Stanley to withdraw as attorney for BomKwow, Jinelet, Memund, Shidaile, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok. New address information: Contact information provided within brief Presented before Magistrate Ju 68

MINUTE entry before the Honorable Heather K. McShain: Telephone conference held on 09/14/2023. Defense counsel Michael Stanley has moved to withdraw 68 with respect to the remaining defendants with whom plaintiff was attempting to settle, specifically defendants 83, 74, 43, 11, 39, 40, 75. Defense counsel mistakenly presented the motion to withdraw before the Magistrate Judge. The motion to withdraw 68 is denied without prejudice to defense counsel refiling the motion before District Judge Bucklo and in accordance with Judge Bucklo's notice requirements. Plaintiff intends to move for default judgment as to the remaining defendants in the case. All matters related to the referral completed, the referral is closed. Mailed notice.

SATISFACTION of Judgment as to Defendant no. 141 Givvet-us

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 19 Katrina's Gift and no. 30 insaneness

MOTION by Attorney Michael Stanley to withdraw as attorney for BomKwow, Jinelet, Memund, Shidaile, ZPOKELEGG, akaocozus 7-15 Days Delivery, wehenwok. New address information: Attached as Exhibit 2 to Motion

MINUTE entry before the Honorable Elaine E. Bucklo: Unopposed motion to withdraw as counsel [73] as to Defendants 83 BomKwow, 74 Shidaile, 43 wehenwok,11 ZPOKELEG, 39 Jinelet, 40 Memund-US and 75 akaocozus-US is granted. Attorney Michael Thomas Stanley is terminated. Mailed notice.

MOTION by Plaintiff Rarog j.d.o.o. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendant Nos. 11,39,40,43,74,75 and 83

MEMORANDUM by Rarog j.d.o.o. in support of motion for default judgment 78

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 78 before Honorable Elaine E. Bucklo on 10/11/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment against Defendants Nos. 11, 39, 40, 43, 74, 75, and 83 78 is granted. Enter Default Judgment Order. The Clerk of the Court is directed to return the security bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff RAROG or Plaintiff's counsel, Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois, 60604. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 10/11/2023. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 152 REAXOY Official

SATISFACTION of Judgment as to Defendant no. 54 Snowflakes-s

SATISFACTION of Judgment as to defendant no. 191 pmayu87

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

SATISFACTION of Judgment as to Defendant no. 121 Demaxiye

SATISFACTION of Judgment as to [Certain] defendants

SATISFACTION of Judgment as to Defendant no. 111 Landao Innovations