2023-cv-02421

COMPLAINT filed by Princess Karibo; Filing fee $ 402, receipt number AILNDC-20551540.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Princess Karibo Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Princess Karibo by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Princess Karibo by Yi Bu

ATTORNEY Appearance for Plaintiff Princess Karibo by Adam Grodman

ATTORNEY Appearance for Plaintiff Princess Karibo by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Princess Karibo by Yanling Jiang

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 Princess Karibo for leave to file under seal

MOTION by Plaintiff Princess Karibo for leave to file excess pages

MEMORANDUM in support of 11 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Princess Karibo

(Exhibit 1, of Princess Karibo's declaration)

SEALED EXHIBIT by Plaintiff Princess Karibo Sealed Exhibit 2, Declaration of Princess Karibo regarding memorandum in support of motion, 12

(Exhibit 2-1)

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

INJUNCTION BOND in the amount of $ 10,000 posted by Princess Karibo (Document not scanned)

MOTION by Plaintiff Princess Karibo for preliminary injunction

MEMORANDUM by Princess Karibo in support of motion for preliminary injunction 17

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

SUMMONS Returned Executed by Princess Karibo as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/5/2023, answer due 5/26/2023.

(Declaration of Service)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 17 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by May 12, 2023." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff Princess Karibo regarding order on motion for preliminary injunction, text entry, 20

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 17 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 21 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Jiangip LLC., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Lindsay C. Jenkins on 5/16/2023. Mailed notice.

NEW PARTIES: ZhangLeiHFKJFHIOFHGZSAE, SHUSEN, Ninesanding, xingtuanfuzhuangfushidian, chenxiaoyundianzikeji, zixixiannangebaihuodian, MaricaoStore, BD-Sign, Early Autumn Tapestry Shop, THU HANG CAO SHOP, TRANMINHDUCCITY, jiangxiaofang, NaturalPride, fensen, Plover-, TATAMAO, TaiYuanZhiJiaMaoYiYouXianGongSi, Selling Rainbows, IRFAN ALAM STORE, Le Tuong Nguyen, Ngoctuanpham21, TKLT, Gundrios Eos, TurtleQQQ, Antal-TM, hejinshijubinshangmaoyouxiangongsi, Violet's-Dresser, malelepomn, nzhouchenji, Xielong puzzle, GalahofHome, guangzhouhengtishangmaoyouxiangongsi, senniaojiaju, Zesser, Tukool, TALOGEM, NAMMIN, AUNMER, kunmingguangcenshangmaoyouxiangongsi and CAShaobeiq added to case caption.

NEW PARTIES: FMO LLC, Feixiangus, Zdony, BEESUNFLOWER, KINGSOW, Bravoheart, BigSmileFace, qujingwangleidianzishangwuyouxiangongsi, Geneh, lin guixionglin guixiong, shidoudouzhangda, Joyland Accessories, LANJINDENG, Melinda Lance, Huangzhen88, Santa Gifts Store, Josid, Clothing Slippers Groceries Store, Xbaondb, Mrhuodedian, andinghuaerrankejiyouxiangongsi230, xiaintel, Mourin Shop, Chunxaonet, yujiangquxibeifuzhuangdian, ZHUOYU-US, DingXuBao, YuHangXiangBaoDian, By2 Style, CHENYUMEIMEI, Haima Pretty, KIET TNZOCISDVSDV, A New Rise, NVTSTORE231, Defemim, KOKGYM, MaiMaiTiShaLiAiMaiErsssssssssssss, QIEMIAO and GAF co.ltd added to case caption.

NEW PARTIES: HATTEN store, cptfadh U.S, Denise, Joybuy, Qixin Co. Ltd, FASHIONIAL SHOPPING, WFPLHFT OK, Cloudedge Fushi, befightstore, Hmrjop Co. Ltd, All-season Stores, Good Life Co.Ltd, Coappsuiop Home Decor Co.,Ltd, Ftyeach ltd, Fighty, Vinsonshop, denetytres, Ryawan, Jluckiy, LUUSI, YuanPingHongYanYanQiPeiYouXianGongSi, ipzHeJ clothes store co.Ltd, zhonghuishangmao, liudongkejiyouxiangongsi, Yidarton, Shenzhenfengniaotongxunkejiyouxiangongsi, xiangchengshiwanchuanwangluokejiyouxiangongsi, Fengniao Store Ts, MANCHE, DeRong-BYFW, HONGKONG ZONGYU TRADING CO., LIMITED, shenzhenshikedaerkejiyouxiangongsi, Junjingyi Trading Co., Ltd., SnowCinda, Patioaro, Ningboshi Dajidianzikeji Co.ltd, jiujiangyonghanmuxiaoshou, DGWDBFSYXGS Store and Groceryarc added to case caption.

NEW PARTIES: ' added to case caption.

MOTION by Plaintiff Princess Karibo to substitute party Plaintiff's Unopposed Motion For Leave To Substitute Defendants

MOTION by Plaintiff Princess Karibo to substitute party [Corrected] Plaintiff's Unopposed Motion for Leave to Substitute Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's unopposed motion to substitute Defendant No. 84 Joybuy with "Shenzhen Xiaohuangya Toys Co., Ltd." 24 25 is granted. The Clerk shall substitute the Defendant. Mailed notice.

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

MOTION by Plaintiff Princess Karibo for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Princess Karibo in support of motion for default judgment 28

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 28 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before June 21, 2023. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff Princess Karibo regarding order on motion for default judgment, text entry, 30

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

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 28 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants, the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $50,000 is an appropriate award of statutory damages. Enter Final Judgment Order. Civil case closed. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 6/27/2023. Mailed notice.

SATISFACTION of Judgment as to defendant no.72 Haima Pretty and no.45 BEESUNFLOWER