2023-cv-03602

COMPLAINT filed by Ali Gulec; Filing fee $ 402, receipt number AILNDC-20714436.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Ali Gulec Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Ali Gulec by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Ali Gulec by Adam Grodman

ATTORNEY Appearance for Plaintiff Ali Gulec by Yi Bu

ATTORNEY Appearance for Plaintiff Ali Gulec by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Ali Gulec by Yanling Jiang

CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable M. David Weisman. 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 Ali Gulec for leave to file [Certain] Documents Under Seal

MOTION by Plaintiff Ali Gulec for leave to file excess pages

MEMORANDUM In Support of 11 Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, Declaration of Keith Vogt

Declaration of Ali Gulec

(Exhibit 1, Declaration of Ali Gulec)

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

(Exhibit 2, Part 1)

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for leave to file under seal 9, motion for leave to file excess pages 10, and ex parte motion for a temporary restraining order and other relief 11 are granted in part. Plaintiff's submissions establish that, were Defendants to learn of these proceedings before the execution of Plaintiff's requested preliminary injunctive relief, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, Plaintiff may for now file under seal the documents identified in the motion to seal and appearing at docket entries 2, 11, and 13. The accompanying Temporary Restraining Order shall also be placed under seal. In addition, for the purpose of the motions cited above, Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, and as noted above, were Defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating Plaintiff's interests in identifying defendants, stopping Defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by Plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to Plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer harm caused by the sale of counterfeit items, and there is no countervailing harm to Defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to Defendants. As other judges in this District have noted, there may be reason to question both the propriety of the joinder of all Defendants in this one action and whether Plaintiff will pursue an accounting (which Plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the Court is persuaded that Plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all Defendants. Expedited discovery is warranted to identify Defendants and to implement the asset freeze. If any Defendant appears and objects, the court will revisit the asset freeze and joinder. Enter Sealed Temporary Restraining Order. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable John F. Kness on 7/6/2023. 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 Ali Gulec. (Document not imaged)

MOTION by Plaintiff Ali Gulec for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable John F. Kness: Motion for extension of time 18 is granted. Enter Order. Mailed notice

ORDER on Motion for Extension of Temporary Restraining Order signed by the Honorable John F. Kness on 7/20/2023. Mailed notice

MOTION by Plaintiff Ali Gulec for preliminary injunction

MEMORANDUM by Ali Gulec in support of motion for preliminary injunction 21

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

SUMMONS Returned Executed by Ali Gulec as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/24/2023, answer due 8/14/2023.

(Declaration of Service)

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion 21 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 8/3/2023." 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, as well as in Plaintiff's motion 18 to extend the TRO, the TRO is extended to and including the date on which 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 Ali Gulec regarding terminate deadlines and hearings, terminate motion and R&R deadlines/hearings, set motion and R&R deadlines/hearings, 24

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 59 Foruidea

MOTION by Plaintiff Ali Gulec for default judgment as to

MEMORANDUM by Ali Gulec in support of motion for default judgment 27

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

ATTORNEY Appearance for Defendant HEHOAH by Adam Edward Urbanczyk

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for a preliminary injunction [21] is granted. Plaintiff's filings establish that Plaintiff 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 [25] 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, despite the Court having provided [24] the opportunity to do so, no Defendant has objected to the motion for a preliminary injunction. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Mailed notice

PRELIMINARY INJUNCTION signed by the Honorable John F. Kness on 8/21/2023. Mailed notice

MINUTE entry before the Honorable John F. Kness: Before the Court is Plaintiff's motion [27] 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 8/29/2023. 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 two business days of its entry on the docket and must file proof of service within three business of service being effected. Mailed notice

CERTIFICATE of Service by Plaintiff Ali Gulec regarding terminate deadlines and hearings, terminate motion and R&R deadlines/hearings, set motion and R&R deadlines/hearings, [32]

NEW PARTIES: GuangZhouJianXianMaoYiYouXianGongSi, F_Gotal, Zulmaliu, Grergina, OSTELY, Duanmuci and DuoqunClothing added to case caption.

NEW PARTIES: iYYVV(7-15 days delivery) added to case caption.

NEW PARTIES: Fashion Trendy Store, Vothiphan, VENS LUEE, kerwei, PRDECEXLU, MmNote, LuvlC, YOMXL, sunjinfangamz, laicai, Lombt, YAXING-Lshop, Hot Sale for May-SHAOZI, ADSSDQ, LiDengGaoXIAOdian, XieXiuYuanXiaoDian, weisijia, ziwangjisuanji, wangjingkuajing, shouyangxianluoyueshanghang, JiuShengArt, yun nan chen sen huan jing ke ji you xian gong si, qujingjianjiedianzishangwuyouxiangongsi, huweixiao, huizemojianghulianwangkejiyouxiangongsi0, Cndeyike, Veronika Smirnova's Store, xuchunm llc, dingshangnian, GuiTongShangMaoYouXianGongSi, uytrfghgfdsg, foshanshihengsuyangkejiyouxiangongsi, NAGOYES, DualUS Decor, erfeer, qujingqitaoshangmaoyouxiangongsi, NTT Clothing Store, Giuin, Song Art Store, Dalicoter, Panypost, liyuxin6, Foruidea, Lijunfeng, 247 Fammy, Chengduyouarefushiyouxiangongsi, Gift Vibe, DoxiSupermall, jinliuqiao, FuFuPurple, ANH TIEN SINH STORE, zzh321, enshishihouyueshangmaoyouxiangongsi, Suncolour, fangyustore, Naimuddin Seikh, Chiclook Cool and dongsenshangmaohang added to case caption.

NEW PARTIES: XCwuxunquan, JALYCOS, nunubee, Sanydanc, iSewForDoll Sewing Supplies, Yorick BK, Product World New, You are naughty again., KO-Sign, Sofia0805, Exquisite Life Shop, BD-Sign, GoutSu US, taianbaixiangguomaoyiyouxiangongsi, LIUBOG, malelepomn, Icingg, TyrStore, HVT GLOBAL, Jeliva, luoheshiaocheng, Malala23 Store, qionghaishizijinyushangmaoyouxiangongsi, uanlu8948, WangXiaoDanxiaodian, rbw2415, Map CanVas Store, DianShan YuYu, XieLianglin Art and Changhao Art added to case caption.

NEW PARTIES: Maxhace-USAWithin 8-14 Days Delivery added to case caption.

NEW PARTIES: Tantisy Easter Day Big Promotion added to case caption.

NEW PARTIES: Defendant no. 5, Defendant no. 31, Defendant no. 43, Defendant no. 44, Defendant no. 53, Defendant no. 66 and Defendant no. 92 added to case caption.

MOTION by Defendant HEHOAH for extension of time UNOPPOSED

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

MINUTE entry before the Honorable John F. Kness: In-Person Motion Hearing set for 9/5/2023 at 10:10 AM. Mailed notice

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 1 HEHOAH

MINUTE entry before the Honorable John F. Kness: In view of the stipulated dismissal [37] filed today, the motion [34] for an extension of time to respond by Defendant HEHOAH (Def. 1) is dismissed as moot. The in-person motion hearing set for 9/5/2023 is stricken. Plaintiff's motion [27] for default judgment is taken under advisement and will be resolved by separate order. Mailed notice

ORDER signed by the Honorable John F. Kness on 9/5/2023: Plaintiff's motion for entry of default judgment [27] is granted. Enter Final Judgment Order. The ten-thousand-dollar ($10,000) surety bond posted by The Gulec is hereby released to Gulec or its counsel, Keith A. Vogt. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Keith A. Vogt of Keith Vogt Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois, 60604 via certified mail. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER signed by the Honorable John F. Kness on 9/5/2023. Mailed notice

MAILED out the ten thousand dollars ($10,000) surety bond posted by Plaintiff to Keith A. Vogt, via Certified Mail Receipt Article Number: 7019 2280 0000 0962 9313.

RETURN of U.S. Post Office Receipt, article no. 7019 2280 0000 0962 9313 executed on 09/11/2023.

SATISFACTION of Judgment as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 39 Cndeyike