2023-cv-04342

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 402, receipt number AILNDC-20804940.

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SCHEDULE A by Plaintiff Dyson Technology Limited Schedule A regarding complaint 1 Modified on 7/25/2023.

CASE ASSIGNED to the Honorable Nancy L. Maldonado. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. 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.

EXHIBIT 1 PARTS 1-5 by Plaintiff Dyson Technology Limited Exhibit 1 - Parts 1-5 regarding complaint 1 Modified on 7/25/2023.

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Exhibit 1-4

(Exhibit 1-5)

MOTION by Plaintiff Dyson Technology Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dyson Technology Limited

Notice of Claims Involving Patents by Dyson Technology Limited

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Lawrence J. Crain

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

MAILED patent report to Patent Trademark Office, Alexandria VA

AMENDED complaint by Dyson Technology Limited against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SCHEDULE A by Plaintiff Dyson Technology Limited Schedule A regarding amended complaint 13 Modified on 7/25/2023.

EXHIBIT 1 by Plaintiff Dyson Technology Limited Exhibit 1 regarding amended complaint 13 Modified on 7/25/2023.

(Exhibit 1)

MOTION by Plaintiff Dyson Technology Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Dyson Technology Limited in support of motion for temporary restraining order 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion 17

(Exhibit 1)

DECLARATION of Giles Samuel Lane - Exhibit 2 by Plaintiff Dyson Technology Limited Exhibit 2 regarding declaration 19 Modified on 7/25/2023.

(Exhibit 2)

MOTION by Plaintiff Dyson Technology Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Dyson Technology Limited in support of motion for miscellaneous relief 21

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 22

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Nancy L. Maldonado: For the reasons set forth in Plaintiff's motions, the supporting memoranda, and the temporary restraining order, Plaintiff's motions for leave to file under seal 4, for electronic service of process 21, and for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 16, are granted. Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, were Defendant 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 the individuals and entities operating Defendant, stopping Defendant's infringing conduct, and obtaining an accounting. In addition, the evidence submitted by Plaintiff shows a substantial likelihood of success on the merits (including evidence of active infringement and sales into Illinois), the harm to Plaintiff is irreparable, and an injunction is in the public interest. 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. See, e.g., Oakley, Inc. v. P'ships & Unincorporated Ass'ns Identified in Schedule "A," No. 20-CV-05049, 2021 WL 2894166, at *5 (N.D. Ill. July 9, 2021) (finding electronic service proper in similar circumstances). Expedited discovery is warranted to identify Defendants and to implement the asset freeze. Plaintiff shall deposit with the Clerk of Court one thousand dollars ($1,000.00), either cash or surety bond, as security.

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Nancy L. Maldonado on 7/12/2023. Mailed notice. Modified on 7/25/2023.

Registry Deposit Information Form by Dyson Technology Limited

BOND in the amount of $ 1,000 check, Receipt No. 4624288788, posted by Dyson Technology Limited

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

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction

(Exhibit A)

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction 27

Declaration of Jake M. Christensen

(Exhibit 1)

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/21/2023, answer due 8/11/2023.

(Declaration of Andrew D. Burnham)

MINUTE entry before the Honorable Nancy L. Maldonado: Plaintiff's motion for entry of a preliminary injunction 27 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns & Crain, Ltd. is ordered to add Defendant's name listed on the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Nancy L. Maldonado on 7/24/2023.

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MINUTE entry before the Honorable Nancy L. Maldonado: Pursuant to the notice of dismissal under Rule 41(a)(1), Plaintiff's claims against Defendant a_cellbattery are dismissed without prejudice. The dismissal shall automatically convert to a dismissal with prejudice after a period of 270 days from the date of this order, if no motion for leave to reinstate the case is filed before the end of that period. Civil case terminated.

MAILED patent report and certified copy of order dated 8/4/2023 to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Dyson Technology Limited for Release of Bond

MINUTE entry before the Honorable Nancy L. Maldonado: Plaintiff's motion for release of bond 35 is granted as this case has been voluntarily dismissed. The Clerk of the Court is directed to return the $1,000 cash bond, including any interest minus the registry fee, previously deposited with the Clerk of the Court to Plaintiff or its counsel by check made out to the Greer, Burns & Crain IOLTA account. Enter Order to Release Bond to Plaintiff.

ORDER to release bond to Plaintiff Signed by the Honorable Nancy L. Maldonado on 8/10/2023.