2023-cv-02308

COMPLAINT filed by Nike, Inc.; Filing fee $ 402, receipt number AILNDC-20535063.

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

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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 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[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Joe Pallett regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-8 regarding declaration[14]

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

(Exhibit 3-8)

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[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

MEMORANDUM by Nike, Inc. Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum[19]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion to seal 3, ex parte motion for a temporary restraining order 11, and motion for electronic service of process 16. Enter Sealed Temporary Restraining Order. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on April 26, 2023 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 4/18/2023. Emailed notice

SURETY BOND in the amount of $ 10,000 posted by Nike, Inc. (Document not Scanned)

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

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

MEMORANDUM by Nike, Inc. in support of extension of time 24

(Declaration of Jake M. Christensen)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the accompanying memorandum, the Court grants Plaintiff's Motion to Extend the Temporary Restraining Order [24]. The Temporary Restraining Order [22] shall now expire on May 24, 2023 at 6:00 p.m. Mailed notice.

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 preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[29]

Declaration of Jake M. Christensen

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/22/2023, answer due 6/12/2023.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion and the accompanying memorandum, Plaintiff's motion for an entry of a preliminary injunction [29] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 3 to the Declaration of Joe Pallett [15] [15-1] [15-2] [15-3] [15-4] [15-5] [15-6] [15-7] [15-8]; and (3) the TRO [22]. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Franklin U. Valderrama on 5/23/2023. Mailed notice.

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

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/26/2023, answer due 6/16/2023.

NEW PARTIES: Hunan Kangxuan Technology Co., Ltd., Yangzhou Step Toys & Gifts Co., Ltd., HapSonda Store, HKYC Wholesale Top Discount 50 Store, Hongtu shoe store Store, HYM HLJ FDH Mingjing shoe factory Store, JINANDYU Manufacturers dropshipping Store, KANPA Store, Kavsenraies Official Store, LLDQN&IFVA NIUYANG Store, LUCK 007 Store, Lukeni JR Store, Luxky old friends Store, LVLUO Official Store, LX088 Store, mj007 Store, MLC NO1 Store, mosodo clothes & accessories Store, MUPLY Bebes Store, Newlife World Service Store, Nuo Peng E-Commerce Company Store, Official Brand Shoes Store, OLOMMOO Store, Party college school Store, Personalized shoe store Store, Phenomenal Store, Professional basketball shoes Store, QZHSMY Official Store, Realheren Official Store, Rozoball Factory dropshipping Store, Sanguine Athena Store, Shop1100063024 Store, Shop1100218373 Store, Shop1100219743 Store, Shop1100219747 Store, Shop1100227438 Store, Shop1102061892 Store, Shop1102081326 Store, Shop1102127703 Store, Shop1102129254 Store, Shop1102233035 Store, Shop1102244103 Store, Shop1102244980 Store, Shop1102289034 Store, Shop1102291075 Store, Shop1102291376 Store, Shop1102346521 Store, Shop1102347502 Store, Shop1102435723 Store, Shop2292094 Store, Shop3680020 Store, Shop4660015 Store, Shop5052161 Store, Shop5063123 Store, Shop5780119 Store, Shop5800775 Store, Shop911188247 Store, Shop912626426 Store, shopxiaohong Store, SK Basketball Shoess Store, SPCN PROJECTX Official Store, The Two Dimensional Association toy Store, Toy manufacturer Store, wenqshoes Store, wetrics -shoes Store, WLYF Store, Wnogfkue Store, Woniso Store, WSAPP 86-15900520352 Store, WWWWWMMMMM Store, XDUNED Factory Store, XIAOMI Boutique Watch Store, xiaoxiaofushi3 Store, XPAY Profession Store, YANA COS Store, yanlu123 Store, Yearning life in the Store, YH Flagship Store, YINCHUAN Dropshipping Store, YSOKRAJ Official Store, Yucheng shoe store Store, yukobe Store, YZLOXL Love-Sports Store, zh1992 Store, ZIJIAN Official Store, Zz Trend Store, hanzanyouxuan, HARAVAL, hefeijiesengwangluokejiyouxiangongsi, hezepengwangwangluokejiyouxiangongsi, HouseUS321, HuJiangYM, Jniehuse, JoanBo, LiJH, LiLanYingUS, LINYARU US, Living Artist, LiYuChengAnQingTianChuShangMao, Lloopyting(Delivery within 7-15 days), mahongrongdianzikeji, MENGTIANMUMEN, Mevlzz-US, MSSuger, mxzy-AM, NIKE AIR SHOES, Potton, qingshanqu02, quanzhoumingshumaoyiyouxiangongsi, shengdiege, shizhenquandianpu723e, skysea123, Small backpack shop, Socviis-Sport, TACA-H, TieXJ, Twinkle-Hope, Wangyi Hundred Goods USA, wenshuixianruibindianzikejiyouxiangongsi, yangshen1002, YaoSyu, Yitown, yunxiaoxianchengzibaihuodian, yunxiaoxiancidongbaihuodian, yunxiaoxianhechebaihuodian, yunxiaoxianyaoxiangbaihuodian, Yunxiaoxianyuelianbaihuodian, zhangjingdedianpu, ZhangXiaoDHG, zhifanjianzhulaowushop, zhuacom, januarysnow, marchwind Store, qq1959578427, se7encp021, thepuffer, tybd7785321, happy202011, hdjneonsign, hoolywow0, hxkeepgoing, hxstartingline, isabellallgeek, jiangxin992, jienawu, missladyone, newgame01, orangejuice-0, outdoor1916, pandashoes2012, pgone9, pocari5, raneee, satoru-1, sportyandcomfy, syngizm-82, tillman-lcz, try-everything, yangse305, yoga_style, zhong180, kickwell.999, HCMY Co.Ltd, Hetohec, Hiigyl, hunanshengtingfeidianzishangwuyouxiangongsi, JJ tiger, Juebong, MianYangBinBinLuo, nanchongzhonghanghengdianzishangwuyouxiangongsi, Tony Noah.LLC, TYLBkk.CLEARANCE, WWNER, xuezhiyanshangmaoltd, Yinsihan, Yishow Trading, Your choice Co. Ltd, yubikelmi Co.Ltd, ly55020457.x.yupoo.com, rosasneaker.top, Uncle Brynn and liaohui7234 added to case caption. (Text entry; no document attached.)

Declaration of Marcella D. Slay

(Exhibit A)

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

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

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 all Defendants, MOTION by Plaintiff Nike, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[40]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[41]

Exhibit 1

ATTORNEY Appearance for Defendant Yinsihan by Adam Edward Urbanczyk

MOTION by Defendant Yinsihan for extension of time

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant Yinsihan's Motion For Extension of Time [44]. Defendant Yinsihan's deadline to respond to Plaintiff's complaint is extended to 07/11/2023. Emailed notice

MINUTE Entry before the honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment [40]. Statutory damages are awarded in the amount of $200,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order. By 7/21/2023, Plaintiff is directed to file a status report as to the status of the case against the remaining defendants. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Emailed notice

DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 6/22/2023: Emailed notice

FULL SATISFACTION of Judgment regarding order[47] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[47] in the amount of $200,000 as to certain defendant

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

STATUS Report per [46] by Nike, Inc.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the Plaintiff's Status Report [51]. Plaintiff has indicated that Plaintiff and Defendant Yinsihan (No. 188) have reached a settlement in this case. Pursuant to the Default Judgment Order entered as to certain Defendants [47], Plaintiff was advised that in order to obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Based on the Status Report, it appears that the preliminary injunction no longer applies to any Defendant. Accordingly, Plaintiff is directed to file a motion for the return of the bond, and to submit a proposed order to the Court by emailing a Microsoft Word version of the draft to Proposed_Order_Valderrama@ilnd.uscourts.gov. Mailed notice.

MOTION by Plaintiff Nike, Inc. for Release of Bond

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in Plaintiff's Motion for Release of Bond [53], the motion is granted. Enter Order To Release Bond To Plaintiff. Plaintiff's Status Report [51] indicates that all remaining Defendants have been dismissed and the case can be terminated. As all claims against all Defendants have been resolved, this case is closed. Civil case terminated. Emailed notice

ORDER TO RELEASE BOND TO PLAINTIFF: Signed by the Honorable Franklin U. Valderrama on 7/31/2023. Emailed notice

FULL SATISFACTION of Judgment regarding order 47 in the amount of $200,000 as to certain defendant