2023-cv-03385

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 402, receipt number AILNDC-20683844.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

Notice of Claims Involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 Harley-Davidson Motor Company, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Harley-Davidson Motor Company, 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 Adraea M. Brown regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 3 - Parts 1-4 regarding declaration[14]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, 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

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for a temporary restraining order, temporary asset restraint, and expedited discovery 11 is granted. The motions for leave to file certain documents under seal 3 and for electronic service of process 16 are granted. Enter Temporary Restraining Order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 6/2/2023. Mailed notice

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

INJUNCTION BOND in the amount of $ 90,000.00 posted by Harley-Davidson Motor Company, Inc. (Document not scanned).

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/13/2023, answer due 7/4/2023.

Declaration of Berel Y. Lakovitsky

Exhibit A

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction[25]

Declaration of Marcella D. Slay

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [25] is granted. Enter preliminary injunction order. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 6/14/2023. Mailed notice

NEW PARTIES: Dongguan Junli Jewelry Co., Ltd., Guangdong Aep Technology Co., Ltd., Guangzhou Huiyi Textile Technology Co., Ltd., Guangzhou Liwan District Jinyun Jewelry Firm, Guangzhou Zoryn Jewelry Co., Ltd., Hebei Sachi Advertisement Co., Ltd., Linyi Aozhan Import And Export Co., Ltd., Qingdao Ziyi Junchen Trading Co., Ltd., Quanzhou Ruixi Trading Co., Ltd., Shanghai Tongjie Printing Production Co., Ltd., Shenzhen Feshion Trade Co., Limited, Suzhou Repsn Sign Co., Ltd., Wuhan Jw Banner Co., Ltd., Yiwu Huibang Jewelry Factory, Yiwu Sidan E-Commerce Co., Ltd., AIMTE Car Emblem Store, BF-70 Store, Fuhai Tesco Store, Hello Dropship Store, Huihui Luxury 67 Store, JL TOY Store, LoveToolBox Store, Ming Yin Store, NmaxMotor Store, Shop1100215283 Store, Shop1102641071 Store, Shop1102647169 Store, Shop1102665251 Store, Shop1102673462 Store, Shop1102714428 Store, Shop1102732969 Store, Shop1102776769 Store, Shop1102787491 Store, Wesitee Automobile Store, xiaoran-42 Store, Xinxmoto Store, yun950112 Store, A3SVIHKD0UI68F, A3VJBVA9OLGRWY, AL0MQFDC2HAEY, Aneirin, Ccave-us, Ciappexu Direct, dgewioghioegjiowg, dongguantujianshangmaoyouxiangongsi, Flarestar Auto Parts, Flowery boutique For USA, fuqingshiyinxijiedaolintingriyongpinshanghang, gajishangmaoyouxi, gxwuoj, HD flag US, hefengxianzutianshangmaoyouxiangongsi, Ledong Dagu Trading Co., Ltd., luobie, LWTJiangJuYexiaodian, mofom us, Moyanqi, New hooli, Niprden Direct No. 2 Shop, Racsoh-US, Select good luck shop For US, ShangShangHao, shaoyusaoyu, Tyenaza, uehbdb, weihua28282, YanLi BaiHuo, yuqinshop, yushiyuan, yuxihongtaquhuigaoshangmaoyouxiangongsi, zanliyouxiangongsi, ZFEbaihuodian, ZhYong, autotribe188, chushu11, dazzlinghome8, jiangzeming, ljj_sunglasses, neimai, syc168, automotoaccessoriess, automotorbike, fengqi_9241, happypins4u, youtub6461, DancePeanut, DrinkRi, Jingxiyate Trading Co.Ltd, sincerity and tytuoling added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 29 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants numbers 65, 81, 83 are dismissed. Mailed notice

ATTORNEY Appearance for Defendant Shanghai Tongjie Printing Production Co., Ltd. by Zhen Pan

MOTION by Defendant Shanghai Tongjie Printing Production Co., Ltd. for extension of time to file answer regarding complaint[1]

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 33 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants numbers 3, 82, 60, 57 are dismissed. Mailed notice

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/10/2023, answer due 7/31/2023.

Declaration of Berel Y. Lakovitsky

Exhibit A

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Shanghai Tongjie Printing Production Co., Ltd's unopposed motion for extension of time 32 is granted. Its response to the plaintiff's complaint is due 8/4/23. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 36 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants numbers 38, 63, and 64 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 39 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant number 6 is dismissed. Mailed notice

MOTION by Defendant Shanghai Tongjie Printing Production Co., Ltd. for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Shanghai Tongje Printing Production Co., LTD.'s unopposed motion for extension of time to respond to the plaintiff's complaint 41 is granted. The answer or other responsive pleading is due 9/1/23. Mailed notice

MOTION by Defendant Shanghai Tongjie Printing Production Co., Ltd. for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Shanghai Tongje Printing Production Co., LTD.'s unopposed motion for extension of time to respond to the plaintiff's complaint 43 is granted. The answer or other responsive pleading is due 10/2/23. Mailed notice

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Trevor Christian Talhami

MOTION by Defendant Shanghai Tongjie Printing Production Co., Ltd. for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Shanghai Tongjie Printing Production Co., Ltd.'s unopposed motion for extension of time to respond to complaint 46 is granted. The answer or other responsive pleading is due 10/13/23. Mailed notice

MOTION by Defendant Shanghai Tongjie Printing Production Co., Ltd. for extension of time Unopposed Motion for Extension of time

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Shanghai Tongjie Printing Production Co., Ltd.'s unopposed motion for extension of time [48] is granted. Its answer or other responsive pleading is due 10/18/23. Mailed notice

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to a Certain Defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 50 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant number 10 is dismissed from this case. Mailed notice

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, [52]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[53]

Exhibit 1

ATTORNEY Appearance for Defendant Jingxiyate Trading Co.Ltd by Adam Edward Urbanczyk

MOTION by Defendant Jingxiyate Trading Co.Ltd for extension of time UNOPPOSED

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant Jingxiyate Trading Co. Ltd's unopposed motion for extension of time [56] is granted. The deadline for the defendant to answer or otherwise respond to the complaint is extended to 11/14/23. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [52] is taken under advisement. Any objections or responses are due by 11/17/23. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 11/9/23. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [59] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 76 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 61 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 88 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 52 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 11/20/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order[64] in the amount of $150,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 42, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 43. Mailed notice

FULL SATISFACTION of Judgment regarding order[64] in the amount of $150,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 67, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant No. 1. Mailed notice

FULL SATISFACTION of Judgment regarding order[64] in the amount of $150,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [69], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 13. Mailed notice

Full SATISFACTION of Judgment regarding order[64] in the amount of $150,000 as to certain defendant

MINUTE ENTRY ENTERED IN ERROR.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [71], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 78. Mailed notice