2023-cv-02412

COMPLAINT filed by Polyblank Designs Limited; Filing fee $ 402, receipt number AILNDC-20551123.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Polyblank Designs Limited Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Polyblank Designs Limited by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Polyblank Designs Limited by Yi Bu

ATTORNEY Appearance for Plaintiff Polyblank Designs Limited by Adam Grodman

ATTORNEY Appearance for Plaintiff Polyblank Designs Limited by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Polyblank Designs Limited by Yanling Jiang

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Polyblank Designs Limited

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Heather K. McShain. 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 Polyblank Designs Limited for leave to file [Certain] Documents Under Seal

MOTION by Plaintiff Polyblank Designs Limited for leave to file excess pages

MEMORANDUM In Support of [12] Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, Declaration of Keith Vogt

Declaration of David Denholm

Exhibit 1, Declaration of David Denholm

SEALED EXHIBIT by Plaintiff Polyblank Designs Limited Sealed Exhibit 2, Declaration of David Denholm regarding memorandum in support of motion[13]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal [10], motion to exceed page limitation [11], and ex parte motion for entry of a 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 set for a telephonic motion hearing on 4/26/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

MAILED Copyright report to Registrar, Washington DC.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 4/26/2023. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 4/26/2023. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [10], motion to exceed page limitation [11], and ex parte motion for entry of a 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. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2] and (2) Exhibit 2, Parts 1-3 to the Declaration of David Denholm [14]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 4/26/2023 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 5/11/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

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

SURETY BOND in the amount of $ 10,000 posted by Polyblank Designs Limited. (Document not scanned)

MOTION by Plaintiff Polyblank Designs Limited for extension of time for Temporary Restraining Order

MOTION by Plaintiff Polyblank Designs Limited for preliminary injunction

MEMORANDUM by Polyblank Designs Limited in support of motion for preliminary injunction[21]

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith Vogt

SUMMONS Returned Executed by Polyblank Designs Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/10/2023, answer due 5/31/2023.

Declaration of Service

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/11/2023. As discussed on the record, Plaintiff's motion to extend the temporary restraining order 20 is granted. The Court finds good cause to extend the temporary restraining order through 5/18/2023 pursuant to Fed. R. Civ. P. 65(b)(2). Plaintiff's motion for entry of a preliminary injunction 21 is entered and continued. Telephonic motion hearing set for 5/18/2023 at 9:00 AM. Any party wishing to be heard on the motion shall file an appearance and contact the Courtroom Deputy for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 Andrea R. Wood: Telephonic motion hearing held on 5/18/2023. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [21] is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2], (2) Exhibit 2, Parts 1-3 to the Declaration of David Denholm [14], and (3) the sealed temporary restraining order [18]. Plaintiff's counsel is 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 7/6/2023 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 5/18/2023. Mailed notice

NEW PARTIES: AIO Wride Store, Amrico Nilzia, AN HUONG SHOP, baketee, BATERIATEE, BEACH-GIFT, camtien99, Cong thanh 999, Costcok Store, Fox Wears LLC, Fyonshop, Gladiator Fashion Store, Graphic Moon, GuoHuanZhenChenZhenLianTiYuYongPinShangDian, HanJiangQuSanJiangKouZhenChenQiuMingFuZhuangChang, hoangthai123457, HOLDERJI JAN THE ONE, houkanyouxian, HQUANSHOP, Huishangmaomi, Khanhlinh551, LANNIDEYISHENG, LAVITSHOP, LE GRAND CROWN, LE VAN HUNG SHOP, Linaoshangmaoyouxiangongsi, lingshuigaoyuanwangluokejiyouxiangongsi, LinJiaXin KanQu, liuyangshiyeliangdianzishangmaoyouxiangongsi, LY THI NGUYEN SHOP, MaoSongJingMao, MengZhaoShangMaoYouXianGongSi, Mounts Store US, NHUNG STORE THE ONE, Nice Print - US, Ntlong, PHAM THI THANH NHAN STORE, POLOEMIAK MOEIDK, putianchengxiangqulixingshengbaihuoshanghang, qionghaizhouxiaxiwangluokejiyouxiangongsi, QKIODS-HK, Quoc Huy Shop, SCCHICK, shcs5skcjn, sjcdedian, Suake, sunzhenggui and Tandung added to case caption.

NEW PARTIES: ng Th Thiu and Nguyn Phc Hi Phng 15 added to case caption.

NEW PARTIES: TenShang, Thanh yuu Tho, thiha99, THU HANG CAO SHOP, THUYEN2000, uncenshuijm, VAN.VU.xHai2, Viiii buiii shiopp, WeiZhuangZhuangShiJianRongXin, YouMeJingMao, youweichaomaidehao and ZhouCongDSJKVHJXHKJDSKVDFS added to case caption.

NEW PARTIES: Defendant no. 63 added to case caption.

MOTION by Plaintiff Polyblank Designs Limited for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Polyblank Designs Limited in support of motion for default judgment[27]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against the defendants identified in the first amended Schedule A [27] will be heard at the telephonic hearing set for 7/6/2022 at 9:45 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 11 Fox Wears LLC

ATTORNEY Appearance for Defendant BEACH-GIFT by Wesley E. Johnson

ATTORNEY Appearance for Defendant BEACH-GIFT by Wesley E. Johnson (Amended)

MOTION by Defendant BEACH-GIFT to dismiss for lack of jurisdiction

MEMORANDUM by BEACH-GIFT in support of motion to dismiss/lack of jurisdiction 33

(Declaration)

ATTORNEY Appearance for Defendant BEACH-GIFT by Shu-yu Lin (Lin, Shu-yu)

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

MOTION by Plaintiff Polyblank Designs Limited to stay regarding MOTION by Defendant BEACH-GIFT to dismiss for lack of jurisdiction 33, MOTION by Plaintiff Polyblank Designs Limited for discovery for leave to conduct jurisdictional discovery

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

ATTORNEY Appearance for Defendant THUYEN2000 by Erin Kathryn Russell

MOTION by Defendant THUYEN2000 for extension of time to file answer regarding complaint 1

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 7/6/2023. Counsel for Defendant BEACH-GIFT did not appear. For the reasons stated on the record, Defendant THUYEN2000's motion for extension of time 39 is granted. Defendant THUYEN2000 is given until 7/20/2023 to answer or otherwise respond to Plaintiff's complaint. The Court takes Plaintiff's motion for leave to conduct jurisdictional discovery 37 under advisement. Briefing on Defendant BEACH-GIFT's motion to dismiss 33 is stayed pending further order of the Court. Additionally, Plaintiff's motion for entry of default and default judgment against the Defendants identified in First Amended Schedule A 27 is taken under advisement. Telephonic status hearing set for 8/3/2023 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 Andrea R. Wood: Telephonic status hearing held on 8/3/2023. For the reasons stated on the record, Defendant BEACH-GIFT's motion to dismiss 33 and Plaintiff's motion to stay Defendant's motion 33, and for leave to conduct jurisdictional discovery 37 are terminated as moot in light of the parties having reached a negotiated resolution. Plaintiff's motion for entry of default and default judgment against the Defendants identified in First Amended Schedule A 27 is granted. Enter Default Judgment. Telephonic status hearing set for 8/17/2023 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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 Andrea R. Wood: Telephonic status hearing held on 8/17/2023. As discussed on the record, by 9/14/2023, either the parties shall file dismissal papers or Defendant BEACH-GIFT shall file its renewed motion to dismiss Plaintiff's complaint. Telephonic status hearing set for 9/14/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/14/2023.Mailed notice

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 55 THUYEN2000

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 9/14/2023 and continued to 10/5/2023 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 6 BEACH-GIFT

MINUTE entry before the Honorable Andrea R. Wood: The remaining parties having filed a stipulation of dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii) 46, the claims against Defendant BEACH-GIFT are dismissed without prejudice and with the parties granted leave to reinstate on or before 9/18/2024. If a motion to reinstate is not filed by 9/18/2024, the case shall be dismissed with prejudice without further order of the Court. As all claims against all parties have now been resolved, this case will be closed. All pending hearing dates and motions are stricken. Civil case terminated. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 10 ng Th Thiu and defendant no. 55 THUYEN2000