2023-cv-03866

COMPLAINT filed by Universal Music GmbH d/b/a Bravado; Filing fee $ 402, receipt number AILNDC-20757084.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Universal Music GmbH d/b/a Bravado Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Yanling Jiang

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Yi Bu

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Adam Grodman

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Cameron Eugene Mcintyre

CASE ASSIGNED to the Honorable Joan B. Gottschall. Designated as Magistrate Judge the Honorable Jeffrey I Cummings. 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 Universal Music GmbH d/b/a Bravado for leave to file under seal

MOTION by Plaintiff Universal Music GmbH d/b/a Bravado for leave to file excess pages

MEMORANDUM in support of [11] Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-2, of Keith A. Vogt's declaration

Declaration of Alexa Struck

Exhibit 1, of Alexa Struck's declaration

SEALED EXHIBIT by Plaintiff Universal Music GmbH d/b/a Bravado Sealed Exhibit 2, Declaration of Alexa Struck regarding memorandum in support of motion, [12]

CERTIFICATE of Service by Plaintiff Universal Music GmbH d/b/a Bravado Ex Parte Motion [11] and Proposed Order

MAILED Trademark report to Patent Trademark Office, Alexandria VA

(List of Trademarks Ex. 1)

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

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff is advised that no substantive action may be taken until all notifications as to affiliates required by Local Rule 3.2 have been filed. All notifications as to affiliates required by Local Rule 3.2 must be filed on or before 6/29/2023. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a motion [11] for temporary restraining order. Plaintiff's motion is ex parte as to the defendants, but plaintiff has given notice of the motion [14] to the non-party providers of services to the defendants named in the proposed temporary restraining order (collectively "third-party providers"). The third-party providers have until noon on Thursday, June 29, 2023, to object to plaintiff's request that the court find that it has personal jurisdiction over them and that they are in active concert or participation with the defendants named in schedule A to the complaint. See Fed. R. Civ. P. 65(d)(2). The third-party providers may file an objection in writing or request a hearing, to be conducted via teleconferencing, by sending a message to Chambers_Gottschall@ilnd.uscourts.gov, with a copy to all counsel of record, on or before noon on Thursday, June 29, 2023. Plaintiff is ordered to serve the third-party providers with a copy of this order on or before June 23, 2023. Plaintiff must file a certificate of service on or before June 26, 2023. Mailed notice

CERTIFICATE of Service by Plaintiff Universal Music GmbH regarding text entry, [18]

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Universal Music GmbH

ATTORNEY Appearance for Objector ContextLogic Inc by Christine Elizabeth Skoczylas

OBJECTIONS of Non-Party ContextLogic Inc.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ContextLogic Inc

MINUTE entry before the Honorable Joan B. Gottschall: Non-party ContextLogic Inc. ("ContextLogic"), filed an objection 22 to plaintiff's motion for a temporary restraining order in which it states, "Although ContextLogic is a non-party, it does not dispute or contest the Court's jurisdiction over it with respect to the enforcement of a temporary restraining order proposed by Plaintiff that may be entered in this case or any obligations that ContextLogic may have thereunder." ECF No. 22 at 2. ContextLogic further states that it "does not understand Plaintiff to be alleging that ContextLogic is acting in active concert or participation with the named defendants," but it "specifically objects" to any such finding by the court. Id. at 2-3. Based on ContextLogic's non-opposition to the requested relief, plaintiff's motion 11 for temporary restraining order is granted. The court makes no finding on whether ContextLogic is acting in active concert or participation with the named defendants. Also granted are plaintiff's motion 10 for leave to exceed the Local Rule 7.1 page limit and motion 9 for leave to file Schedule A to the complaint 2 and Exhibit 2 13 to the declaration of Alexa Struck under seal. Enter sealed temporary restraining order. A preliminary injunction hearing to be held by teleconference is tentatively set for July 14, 2023, at 10:30 a.m. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 2 to the declaration of Alexa Struck and any e-mail addresses provided for defendants by third parties that includes a link to said website. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Joan B. Gottschall on 6/30/2023. Mailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Universal Music GmbH.

MOTION by Plaintiff Universal Music GmbH for extension of time of the Temporary Restraining Order

Tentative NOTICE of Motion by Keith A. Vogt for presentment of extension of time[27] before Honorable Joan B. Gottschall on 7/14/2023 at 10:30 AM.

MINUTE entry before the Honorable Joan B. Gottschall: The deadline of 7/12/2023 at 10:30 a.m. to request a hearing has come and gone (see [24]), and no request for a hearing has been received. Plaintiff's motion [27] to extend the sealed temporary restraining order [25] to and including 7/28/2023 is granted. Enter order. The preliminary injunction hearing tentatively set for 7/14/2023 at 10:30 a.m. is stricken and reset to 7/28/2023 at 10:30 a.m. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 2 to the declaration of Alexa Struck and any e-mail addresses provided for defendants by third parties that includes a link to said website.Mailed notice

ORDER ON MOTION FOR EXTENSION OF TEMPORARY RESTRAINING ORDER. Signed by the Honorable Joan B. Gottschall on 7/13/2023. Mailed notice

MOTION by Plaintiff Universal Music GmbH for preliminary injunction

MEMORANDUM by Universal Music GmbH in support of motion for preliminary injunction 31

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

Tentative NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 31 before Honorable Joan B. Gottschall on 7/28/2023 at 10:30 AM.

MOTION by Plaintiff Universal Music GmbH for Electronic Service of Process Pursuant To Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Universal Music GmbH in support of motion for miscellaneous relief 34

Declaration of Keith A. Vogt

(Exhibit 1-2, Declaration of Keith Vogt)

MINUTE entry before the Honorable Joan B. Gottschall: The court having received no request for a hearing by the deadline [29] of 7/26/2023, the preliminary injunction hearing set for 7/28/2023 is stricken. Plaintiff's motion for preliminary injunction [31] and motion for electronic service of process [34] are granted. Enter preliminary injunction order. In accordance with the order, the clerk is directed to unseal Schedule A to the complaint [2], Exhibit 2 to the Declaration of Alexa Struck [13], and the temporary restraining order [25]. The law firms of Keith Vogt, Ltd., and JiangIP LLC are hereby ordered to add ALL defendant names listed in 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. The next status report is due on or before 8/30/2023. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Joan B. Gottschall on 7/27/2023. Mailed notice

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

SUMMONS Returned Executed by Universal Music GmbH as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/28/2023, answer due 8/18/2023.

(Declaration of Service)

NEW PARTIES: akincsrmhtmt, anjia fashion, baizhenghua49184, Bienjiesiys coats, cdfgjoboth, chengzhiyu, chenyuan32, DDD66D8, Diane Maxwell, fcdsfs, fengguifen, gajdhdqkuwdjhdjq, gaojinrou56566666543, gemystica, giocovince, Hkwid, jdsm, JDTJbxfngfxn, jiaozhenyun, jifangfang2095, Johgfhn Edwards, Jose Maddox, liqingzhi1, litian112233, liyongmei6638, luckyczh, man1314, manushores, MartaOrtizssa, Melissa Haupricht, NancyWalker, NancyZoraiRhBoN, nijuan0735, prolineup, Q WWEQ, qiaohefei, qucaiyu45678, QWQQ6, Robert Budd, s34442ws, SandraGalyon, Saphire Alexus Reyes, sauerlatashia, shanxinting, Songyangyang456, songziwei73722, stnjqqcon, sunjuanyue02213, surprise bb, SusannaRexjRaNgM, tan qin ying 668, tangguobin886823, tangjiayi632154566, tianzhendong7041, Toni Vaughan, vfggh, wangchao661, wanghuanhuan312X, wanghui55031 and wangjinxing18 added to case caption.

NEW PARTIES: wangliang7890, wangmengying51265, weixasaizop23., weiyunping7890, whenzhen, workbovssoer, xiaoxiaoming fashion, xiuweiluong, xolbi, xuhuijun fashion, xumeidan4565489, xuqingyi4029, xuyixiang92330, yangjunli14556, yanglei2897, yanxiaojian358595, yanyan1988, Yessoohh, yewendazahuo, yh971224, YIJIN21, Yinyuming 852, yongyongyuanyuan, Yuan yufang world, yuanxiaoxia938402, yueshuai59147, yuge1234, Yummy Tummies Groceries, ZacharyJoshuakFaA, zaihaonian, zenghuizhen0909, zhanghaopeng115150, zhangmeimei6688, zhangting6637, zhangwen00852, zhangxiang1141, zhangxiaofeng135, zhangxiaolan31080, zhaojie76454, zhaoli97780, zhaosi fashion, zhaoxinming, zhengbob, ZHOUDANFENG, zhoumo6753, zhuangzhouzahuopu, zhuminggang17798, zizengqin123, zouxiaomao567, zuojialei, Zuoly bedings, Zzcorom, 23RETROstore, anqingfeirishangmaoyouxiangongsi, Beijingguoyikangzhongyiyiyuan, bifangyangsheng, BobDFenner, CaoZhen 1, CBU81stor and chengdujianghabowangluokejiyouxiangongsi added to case caption.

NEW PARTIES: ChenJianTeng 1 added to case caption.

NEW PARTIES: chenyaoyonge, Chicken and Duck, danghoang412, Dangthihoangngan123, DDDDDDLLLILILILIZZZXSD, DeliaArt, Dhb54n, DIEPNHUNG BGMXK, DINHMINHHAUKLHA, fanlingxiangdimaoyiyouxiangongsi, fengdawei, GreenLabel, GTGTGYVHPI, guobojing, huzhaomingh, IHeartU, Infected, jet honey, JINFENGFANGFANG, Jocasta Maris shop, JOHNDAVID, K.O. EAWIN GROUP, KHANH HUY ADAM SHOP, Koyo04, langsen, le the duc SHOP, LeeMaleda Shops, lengcui and lidongshenl added to case caption.

NEW PARTIES: liuhongweij, LiuLSGMT, lixuq, lwshangmao, mahanlin, MBTEEPOYNO, MEHMET SAKIN, MINH HUE MA SHOP, MINH TUNZTO, MMDLQPPP, My mother's flower country, nguyen thu hoai, nijn2njimk, phuongthaostore1232002, Precious T Shirts store, Qilunshanghang, Rosabella Store, ruanlinpengjiajudian, SAOOU, SarahLetts, SeanGeorges, SIANSIYAMA SHUE1, skmn2cmkig, tangyanhbgf, TeTeKa Store, THERESA PRESTON, TIEU HOAI EVA SHOP, TIMELONELA, Tjingjing, TTTstor, Twenty five - Twenty one, VHanhhhaosk, Viktoria Art, Vin Store LLC, wangdih, wankanlf, Wawanish22, wengzhifeng, WENYOU TRADING LIMITED, WEUIAHSADNBFCID, wulipingzonghelingshoubianlidian, wuwenqiangjhsy, xianyouxianduweizhenzhumaoluroudian, xiaoyuxing, XingDianShangMao, xingyani, xushaoyangf, yangminglikk, Yanxue, YeHuiMinShangHang, yiwanbommQ, YMH64, ZhaoDongDong Trading Co. Ltd, ZHENGFANFAN, zhouxingyuh, ZOROZZW, ZOUSUO-SHOP and ZYIINGHU added to case caption.

MOTION by Plaintiff Universal Music GmbH for default judgment as to The Defendants Identified In First Amended Schedule A

MEMORANDUM by Universal Music GmbH in support of motion for default judgment[39]

Exhibit 1

Exhibit 2

Exhibit 3

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith A. Vogt

MINUTE entry before the Honorable Joan B. Gottschall: Any written response to, or request for hearing on, plaintiff's motion 39 for entry of an order of default and for entry of default judgment is due on or before September 5, 2023. If no written response or request for a hearing is received by the deadline, the court will assume that non-appearing defendants do not oppose the motion and will rule on the papers. A hearing, to be conducted via teleconferencing, may be requested by sending a message to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and attorneys who have appeared. Plaintiff is ordered to serve non-appearing defendants with a copy of this order and file a certificate of service on or before August 24, 2023. Mailed notice

CERTIFICATE of Service by Plaintiff Universal Music GmbH regarding set motion and R&R deadlines/hearings, 41

STATUS Report by Universal Music GmbH

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 41 of 9/5/2023 to object to plaintiff's motion for entry of default and default judgment has come and gone, and no objection has been filed. Plaintiff's motion 39 for entry of default and default judgment is granted. Enter default judgment. Civil case terminated. Mailed notice.

DEFAULT FINAL JUDGMENT ORDER signed by the Honorable Joan B. Gottschall on 9/8/2023. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 203 ZhaoDongDong Trading Co. Ltd

MINUTE entry before the Honorable Joan B. Gottschall: Because default judgment has been entered 45, the court construes plaintiff's notice 46 voluntarily dismissing defendant no. 203 as a motion under Fed. R. Civ. P. 60(b)(5) to modify the judgment because it has been "satisfied, released, or discharged." As so construed, plaintiff's motion 46 is granted. The default judgment 45 dated 9/8/2024 is amended to reflect that defendant no. 203 (ZhaoDongDong Trading Co. Ltd) is dismissed without prejudice. Mailed notice