2023-cv-02623

COMPLAINT filed by Bigfoot 4x4, Inc.; Jury Demand. Filing fee $ 402, receipt number AILNDC-20581116.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Robert Payton Mcmurray

MOTION by Plaintiff Bigfoot 4x4, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bigfoot 4x4, Inc.

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Maria Valdez. 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 Bigfoot 4x4, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bigfoot 4x4, Inc. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Transfer of the Defendant Domain Names, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for temporary restraining order, 10

Declaration Trent Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 1 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 2 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 3 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 4 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 5 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 6 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 7 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 8 of Trent Declaration

Notice of Claims Involving Trademarks by Bigfoot 4x4, Inc.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal 6 is granted. Plaintiff's motion to exceed page limitation 9 is granted. Plaintiff's 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 10 is granted. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Charles P. Kocoras on 5/3/2023. Mailed notice

SURETY BOND in the amount of $ 10,000 posted by Bigfoot 4x4, Inc.

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Ex Parte motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Ex-Parte Motion to extend the Temporary Restraining Order to and including May 31, 2023 26 is granted. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 62

MOTION by Plaintiff Bigfoot 4x4, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for preliminary injunction 29

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 29

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 29 before Honorable Charles P. Kocoras on 5/30/2023 at 09:30 AM.

SUMMONS Returned Executed by Bigfoot 4x4, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 5/25/2023, answer due 6/15/2023.

MINUTE entry before the Honorable Charles P. Kocoras: Motion hearing set for 5/30/2023 at 9:30 a.m. is stricken. Court will rule by mail. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 73, 164

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Charles P. Kocoras on 6/2/2023. Plaintiff' motion for preliminary injunction 29 is granted. The law firm of Hughes Socol Piers Resnick & Dym, Ltd. is hereby 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 located at www.ilnd.uscourts.gov/instructions. Mailed notice

NEW PARTIES: SUQI, SVILY, tai yuan ya ming shang mao you xian gong si, taiyuandaidengshengdianzishangwuyouxiangongsi, Tool Supply Co., Ltd, Ty motor Co. Ltd., Universal Furniture Co.Ltd, VHUNT Co.Ltd, wuhushiwanzhiquduhuwangluokejiyouxiangongsi, Xiadi Co.,Ltd, xiao jing lan shang mao, xiaoxiwangluokejiyouxiangongsi, yuheshengfangdianzishangwu, zhailiyi, Atlantic Co. ltd, G s Clothing Co.,Ltd, Chongqing Media Develop Co., Ltd, CJ Clothing Co.,Ltd., CM Home Co.Ltd, HUANG BO TOYS FACTORY, bestbest898, deep sea7, dhanisprice, dulmen 59, kingsto 7338, kiss slowly, lahsanj-41, newgaga, next.level.solution, noycoh-89, olgatrade, rc-usland, red16890, winonl35, ziwa-6796 and Shenzhenshiwanchuandianzishangmaoyouxiangongsi added to case caption. (Text entry; no document attached.)

NEW PARTIES: GD-SHOPS, GHH-AMZ-SHOPS, HONGWF, HUYANRU, LLMXZ, milaoshuqijiandian, SANTAIZI, sunnion, taiyuanmupanyoushangmao, xdkj-JYW, xdkj-PJXPJX, xiaodongshop, XOXHXOX-US, 12fr3, ae058 Store, ae158 Store, ae174 Store, ae258 Store, ae289 Store, ae567 Store, ae854 Store, ae957 Store, aeex Store, ai807 Store, ai808 Store, ai810 Store, ai826 Store, ai828 Store, ai830 Store, ao98 Store, asd765 Store, b2m9 Store, cbc13344 Store, cdkq Store, ch9807 Store, dfhj851 Store, e3zg Store, enjg Store, jjhp Store, k2fk Store, kbd3 Store, lka2s Store, lkjh87 Store, pabcq Store and pjlf Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: Kaisai Co.Ltd, Kingyoungall, Kiplyki, kong lai ha dian zi shang, lai an chuang ke ji, Li HB Store, Life House 'S Choice Co.Itd, LJW Grocery Store, MASkyfall, Money Honey, Muenya Co.Ltd, Nanchang Yanxian Electronic Technology Co., LTD, Naughtyhood, pan jue qiang, Peima Department Store, POMELO-YZ, Samickarr, SEFUONI, Seluen Trade LLC, shi jue pan ya shang mao, shuang jue teng shang mao, sitedianzi, Stamzod, SYW E-Commerce, SZ Home Tools Co. Ltd, SZBSY Trading Co. Ltd, SZG Trading Co. Ltd, tai yuan bo yi lai dian zi shang wu you xian gong si, tai yuan fang yu ji, tai yuan ji gang teng, tai yuan jiao te sen ke ji you xian gong si, tai yuan mi xue han shang mao you xian Co. ltd, tai yuan xi pu chen dian zi shang wu you xian gong si, TFDZ Store, TONGMI Co., Ltd, Toyella, TROUYANG Co., Ltd., T s Clothing Co.Ltd, tu jue hu, URNOT, WQQZJJ, XCX STORE, XINAN, XINKAIRUN Co.Ltd, xinxiangshishuaizhenshangmaoyouxiangongsi, YC motor Co. Ltd, Yoslce, you jiang, yu dun gao shang mao, YYNKM, ze chao, zhaolijianzhu, zhe gu le, ZLeternity Co. Ltd and Susong County Canping Department Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: guwen78, tangjianguo, Chaomake Co.Ltd, FUHAPPY Co.Ltd, High Quality Furniture Co.Ltd, HOMEIU Co., Ltd, hua guai lan, HUIJITO Co., Ltd., Ju Xing Tou Zi Zi Xun (Fu Jian Sheng Fu Qing Shi)You Xian Ze Ren Gong Si, jue ru gan shang mao, jue xu gu, Kojanyu, lang guan you, li heng gan wang luo, Lifestyle Co.Ltd, Lingdang, LZH Home Co.Ltd, ma zhai an dian zi, Mianyang Wall Street Education Technology Co., Ltd, MS Home Co. Ltd, Music Co.Ltd, New Energy Import and Export Trade Co.Itd, PG Clothing Co. Ltd, ping mi zha ke ji, PTS Elec Co. Ltd, Satiety Co.Itd, shanxiweishuaishangmao, Shengbai Tong Co.Ltd, Shenzhen Wenxingwang Digital Technology Co., Ltd. and Starlight Gatherer added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 52, 63

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 58

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No.16, 69

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 142, 176,220

ATTORNEY Appearance for Defendants SYW E-Commerce, WQQZJJ, XCX STORE, YYNKM by Adam Edward Urbanczyk

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MOTION by Defendants SYW E-Commerce, WQQZJJ, XCX STORE, YYNKM for extension of time

MINUTE entry before the Honorable Charles P. Kocoras: Motion by Defendants SYW E-Commerce, WQQZJJ, XCX STORE, and YYNKM for extension of time [44] is granted. Defendants SYW E-Commerce, WQQZJJ, XCX STORE, and YYNKM shall answer or otherwise plead by 7/27/23. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 51, 218

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendants SYW E-Commerce, WQQZJJ, XCX STORE, YYNKM by Brian Swift

MOTION by Defendants WQQZJJ, XCX STORE, YYNKM, SYW E-Commerce to dismiss for lack of jurisdiction

Declaration of Mengting Zhang

Declaration of Fu He

Declaration of Chun Qian

Declaration of Hongqiang Zhang

MOTION by Defendants SYW E-Commerce, WQQZJJ, XCX STORE, YYNKM to set aside Preliminary Injunction

Exhibit 1

Declaration of Hongqiang Zhang

Declaration of Chun Qian

Declaration of Fu He

Declaration of Mengting Zhang

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Charles P. Kocoras: Defendants SYW E-Commerce, WQQZJJ, XCX STORE, and YYNKM's motion to set aside preliminary injunction [50] is entered and briefed as follows: Response is due by 8/8/23. Hearing is set for 8/10/23 at 11:00 a.m. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: For the telephonic hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. Counsel of record will receive an email the morning of the telephonic hearing with instructions to join the call. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Mailed notice.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 184

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Opposed Motion for a First Extension of Time to File a Response to Defendants' Motion to Set Aside the Preliminary Injunction and Reset Hearing Date [Dkt. No. 50]

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for extension of time and to reset hearing date [55] is granted. Response to motion to set aside preliminary injunction [50] is due by 8/15/23. Hearing set for 8/10/23 is rescheduled to 8/17/23 at 11:00 a.m. For the telephonic hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record prior to speaking.

MOTION to dismiss Plaintiff's Complaint and Vacate Preliminary Injunction filed by Jie Yushi.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 40, 133

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Opposed Motion for a Second Extension of Time to File a Response to Defendants' Motion to Set Aside the Preliminary Injunction and Reset Hearing Date [Dkt. No. 50]

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for extension of time [59] is granted. Response to motion to set aside preliminary injunction [50] is due by 8/22/23. Telephonic hearing set for 8/17/23 is stricken and reset to 8/24/23 at 10:30 a.m. For the telephonic hearing, parties are to use the following call-in number: (888) 684 8852, conference code 8819984. COUNSEL MUST TYPE IN THEIR NAME WHEN JOINING THE CALL. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record prior to speaking.

MINUTE entry before the Honorable Charles P. Kocoras: Defendant goodsharing's motion to dismiss and vacate preliminary injunction [57] is stricken. Defendant goodsharing has neither an attorney appearance nor a pro se appearance on file. Its motion was filed by an individual, Jie Yushi, who does not appear to be a lawyer. The motion states that "Defendant goodsharing (Doe. 156) is an online store operated by an individual named [Jie Yushi] who locates in Shen Zhen, China." It seems that goodsharing may be a sole proprietorship, in which case it may represent itself pro se but must file a pro se appearance. If goodsharing is a corporation, LLC, or partnership, it must retain counsel in order to proceed. Defendant goodsharing may refile its motion after entering either a pro se appearance or attorney appearance.

MINUTE entry before the Honorable Charles P. Kocoras: Defendant goodsharing is advised that the pro se appearance form is available online at: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_online/ProSeApp.pdf. The Clerk's Office is directed to email a copy of this order, the Court's previous order [61], and a pro se appearance form to mgreatseller@163.com.

E-MAILED a copy of the Court's minute orders dated 8/16/2023 (doc. #'s [61],[62]), and a pro se appearance form to Defendant goodsharing to mgreatseller@163.com. (Text entry; no document attached.)

PRO SE Appearance by Defendant goodsharing.

MOTION by Defendant goodsharing to Dismiss Plaintiff's Complaint, MOTION by Defendant goodsharing to Vacate Preliminary Injunction.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 61

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Charles P. Kocoras: In light of the Notice of Voluntary Dismissal of Defendants SYW E-Commerce, WQQZJJ, XCX STORE, and YYNKM 66 filed on 8/22/23, motion to dismiss 49 is denied as moot and motion to vacate 50 is denied as moot. Hearing set for 8/24/23 is stricken. Additionally, Defendant goodsharing's motion to dismiss and vacate preliminary injunction 64 is entered and briefed as follows: Response is due by 9/19/23; reply is due by 10/3/23. Court will rule by mail.

Order on Motion to Dismiss/Lack of Jurisdiction (Text entry; no document attached.)

Order on Motion to Vacate (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

DOCUMENT ENTERED IN ERROR.

MINUTE entry before the Honorable Charles P. Kocoras: In light of the notice of voluntary dismissal of Defendant goodsharing 68 filed on 9/7/2023, motion to dismiss 64 is denied as moot. Mailed notice

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

DECLARATION of William B. Kalbac Declaration of Service

MOTION by Plaintiff Bigfoot 4x4, Inc. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

(Exhibit A)

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for default judgment 73

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 73

(Exhibit Hierl Exhibit 1)

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 46, 131

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 22

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for entry of default and default judgment against the defendants identified in amended schedule A 73 is granted. Enter Final Judgment Order.

FINAL JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 10/19/2023.

SATISFACTION of Judgment

SATISFACTION of Judgment