2023-cv-04474

COMPLAINT filed by Believe Pursue LLC; Filing fee $ 402, receipt number AILNDC-20819682.

Exhibit 1 to Complaint - Patent

Exhibit 2 to Complaint - Trademark

(Exhibit 3 to Complaint - Provisionally filed under Seal Schedule A to Complaint Slipsheet)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Believe Pursue LLC by Blake C Goebel

SEALED DOCUMENT by Plaintiff Believe Pursue LLC Schedule A to Complaint

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Believe Pursue LLC

CLAIM by Believe Pursue LLC regarding Patent and Trademark

SEALED MOTION by Plaintiff Believe Pursue LLC Modified on 7/12/2023.

SEALED MOTION by Plaintiff Believe Pursue LLC Modified on 7/12/2023.

MOTION by Plaintiff Believe Pursue LLC for leave to file excess pages regarding Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

(Exhibit A - Memorandum of Law in support of Plaintiff's Ex Parte Application for Entry of a Temporary Restraining Order)

DECLARATION of Blake C. Goebel regarding motion for temporary restraining order, 8

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

(Exhibit 6)

DECLARATION regarding motion for temporary restraining order, 8

Exhibit 1 - Patent

(Exhibit 2 - Trademark)

SEALED DOCUMENT by Plaintiff Believe Pursue LLC Ex. 3 (Parts 1-7 of 7) to Brett Beck Declaration

Exhibit 3 (2 of 7)

Exhibit 3 (3 of 7)

Exhibit 3 (4 of 7)

Exhibit 3 (5 of 7)

Exhibit 3 (6 pf 7)

(Exhibit 3 (7 of 7))

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable Sunil R Harjani. 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.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff is put on notice that it may be required to file a memorandum discussing the propriety of joinder under Federal Rule of Civil Procedure 20(a)(2) if it appears that defendants are too numerous or unconnected. In addition, should default judgment enter against defendant(s), Plaintiff should be prepared to prove up damages by affidavit or hearing. Mailed notice. (ym,)

MAILED patent report to Patent Trademark Office, Alexandria VA.

NOTICE by Believe Pursue LLC of Filing of Amended Civil Cover Sheet

(Exhibit Amended Civil Cover Sheet)

NOTICE of Motion by Blake C Goebel for presentment of motion for temporary restraining order 8, motion to seal 7, motion for leave to file excess pages, 9 before Honorable Sharon Johnson Coleman on 7/26/2023 at 10:00 AM.

ENTERED In Error. (ym) Modified on 7/24/2023.

NOTICE of Correction regarding docket entry 17.

ATTORNEY Appearance for Plaintiff Believe Pursue LLC by Shannon Joyce Prince

MINUTE entry before the Honorable Sharon Johnson Coleman: Presentment of plaintiff's sealed motion 7, 8 and motion to exceed page limitation 9 set 7/26/2023 at 10:00 AM will proceed as an in-person hearing in courtroom 1241. Mailed notice.

ATTORNEY MOTION by Plaintiff Believe Pursue LLC for leave to appear as ATTORNEY

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 7/26/2023. Attorney Jon Neulieb's motion for leave to file his appearance 21 is granted. Plaintiff to file an amended complaint to cure the joinder issues by 8/16/2023. An in-person status hearing is set for 8/22/2023 at 10:00 AM. Plaintiff's sealed motions 7, 8 and motion to exceed page limitation 9 are entered and continued. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Minute entry 22 is corrected as follows: Motion hearing held on 7/26/2023. Attorney Jon Neulieb's motion for leave to file his appearance 21 is granted. Plaintiff to file a memorandum or statement to cure the joinder issues by 8/16/2023. An in-person status hearing is set for 8/22/2023 at 10:00 AM. Plaintiff's sealed motions 7, 8 and motion to exceed page limitation 9 are entered and continued. Mailed notice.

ATTORNEY Appearance for Plaintiff Believe Pursue LLC by David Edward Hutchinson

STATEMENT by Believe Pursue LLC Establishing that Joinder is Proper

DECLARATION of Blake Goebel regarding statement 25

Exhibit 1 - Unpublished Cases

Exhibit 2 - News Article

Exhibit 3 - WSJ Article

(Exhibit 4 - U.S. CBP Report)

MINUTE entry before the Honorable Sharon Johnson Coleman: The in-person status hearing set for 8/22/2023 is stricken and reset to 9/6/2023 at 10:00 AM. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 9/6/2023. Plaintiff's sealed motions [7,8] and motion to exceed page limitation 9 are all granted. Enter Order. An in-person status hearing is set for 9/20/2023 at 9:00 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 9/6/2023. Mailed notice.

ATTORNEY Appearance for Plaintiff Believe Pursue LLC by Rossana Baeza

Registry Deposit Information Form by Believe Pursue LLC $5,000 Deposit

MINUTE entry before the Honorable Sharon Johnson Coleman: The in-person status hearing set for 9/20/2023 at 9:00 AM is reset to 10:00 AM (NOTE TIME CHANGE ONLY). Mailed notice.

NOTICE of Motion by Rossana Baeza for presentment of EX PARTE MOTION by Plaintiff Believe Pursue LLC to Extend Temporary Restraining Order 32 before Honorable Sharon Johnson Coleman on 9/20/2023 at 10:00 AM. Docket Text Modified by Clerk's Office on 9/15/2023.

MOTION by Plaintiff Believe Pursue LLC to withdraw attorney of record David E. Hutchinson

(Affidavit in Support of Plaintiff's Motion for Withdrawal)

MOTION by Plaintiff Believe Pursue LLC to withdraw attorney of record Shannon Prince

(Affidavit in Support of Plaintiff's Motion for Withdrawal)

NOTICE of Motion by Rossana Baeza for presentment of motion to withdraw 36, motion to withdraw 35 before Honorable Sharon Johnson Coleman on 9/20/2023 at 10:00 AM.

ATTORNEY Appearance for Plaintiff Believe Pursue LLC by Alisha Moriceau

NOTICE by Believe Pursue LLC re Filing Proposed Summons in compliance with Court's Sealed Temporary Restraining Order dated September 6, 2023

(Proposed Summons)

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 9/20/2023. Plaintiff's sealed motion 32 is granted. Enter Order. Plaintiff's motions for withdrawal of attorney of record 35 and 36 are granted. Attorneys David E. Hutchinson and Shannon Prince terminated. An in-person status hearing is set for 10/4/2023 at 10:00 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 9/20/2023. Mailed notice.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A to the Complaint

MOTION by Plaintiff Believe Pursue LLC for preliminary injunction

Memorandum of Law in Support of Motion for Entry of a Preliminary Injunction

(Declaration of Alisha Moriceau)

NOTICE of Motion by Alisha Moriceau for presentment of motion for preliminary injunction 42 before Honorable Sharon Johnson Coleman on 10/4/2023 at 10:00 AM.

NEW PARTIES: didi29455 (1), Hcshop (2), jiamaojiatishangdian (3), zhiyewenh (4), aiyue2020 (5), bohh (6), chao07 (7), jiz8 (8), lquddv2317gx (9), phonglongele02 (10), s9v8 (11), tb0w (12), tianhuosx (13), u4f8 (14), womg (15), ytbe (16), 144mph-oz (17), 144mph-uk (18), chihyupi (19), excellentsale004 (20), frysk974 (21), gaojian13 (22), gfar8ahy (23), kehuas-40 (24), kelsap2016 (25), longlishangmao (26), nohus-6050 (27), tablode (28), topoutlet2018 (29), xiyuanmio3 (30), ydanqing-0 (31), yingenuous (32), zheli254 (33), zhouxiangjun13078720695 (34), Zhendi Fu (35), All Mine Co.,Ltd (36), Beethoven.Co,Ltd (37), Best Way of Life Co.,Ltd (38), Bonsuk Co. Ltd (39), Brittany Co.,Ltd (40), BRRNOO (41), Ccdes Store (42), CZ TRADE Co.Ltd (43), De Xing Yang Store (44), DragonRockBK Co. Ltd (45), Ekeka (46), Exercabest Fitness Co. Ltd (47), First Choice For You (48), Good Choice Co.,Ltd (49), guangzhouyingdaishangmaoyouxiangongsi (50), handanshuzaiyunshangshuzikejiyouxiangongsi (51), HE FEI KUO JUAN WANG LUO KE JI YOU XIAN GONG SI (52), hefeiloumoliaoshangmaoyouxiang (53), Home Management Co.,Ltd (54), HuaShao LLC (55), Jingzhi Trading Co., Ltd. (56), Just For You (57), LINNAO Ltd (58), MEZOOM (59), Mightlink (60), MYYSE.Co,Ltd (61), Nanningkuanglieshang (62), Putianshilichengquzhanghaohaomaoyiyouxiangongsi (63), Raylon (64), Rong Yun Co. Ltd. (65), SEELOK (66), shanghaiquanxincanyinguanliyouxiangongsi (67), shanghairongrandianzikejiyouxiangongsi (68), shenzhenshifanyilinshipinyouxiangongsi (69), shenzhenshiweihanglingchuangwangluokejiyouxiangongsi (70), Superior Co.,Ltd (71), tai yuan hui sheng fei ke ji you xian gong si (72), taiyuanchimuerdianzishangwuyouxiangongsi (73), taiyuanweichenlishangmaoyouxiangongsi (74), Taiyuanzhuohanamaoyiyouxiangongsi (75), TAZEMAT (76), tonghexianlinglangshangmao (77), TOPM Co.,Ltd (78), Unbeatable Sale Store (79), Vinegarsun (80), Wanyihong STORE (81), Wenchangliuzuohushangmaoyouxiangongsi (82), xiangchengshizhangmeishangmao (83), xinhuadsh (84), Xinxiangheng (85), yang zhou qi xing ti yo yong pin you xian gong si (86), yantaitaihuichufangdianqijingxiaoyouxiangongsi (87), Yekida Trade Co., LTD d/b/a Cuhas (88), yiwushilayuhaochengkejiyouxiangongsi (89), YQT (90), yu tao ji dian zi (91), YUEteabar Co. Ltd (92), YZFUS LLC (93), ZEMAY.CO,Ltd (94), zhengzhoulianwushangmaoyouxiangongsi (95), zhengzhouxiajiashangmaoyouxiangongsi (96), 1480162439@qq.com (97), 3268429405@qq.com (98), AbrO (99), Aimensan (100), arin366 (101), BOYSyidian (102), CCcation (103), chenjingbaoxi (104), chenshumi (105), concord66 (106), ercnana (107), FireGluvzDOTCOM (108), fodsports (109), FUJIAN C-long Flly Co.,Ltd (110), Happiness in the Shop (111), harford68 (112), houg_uk2014 (113), hqb (114), JiangXLin (115), jingjingen (116), kuailechongbai (117), lclxihuantree (118), liuyumei (119), liuzhifen (120), lizixiao (121), LOVEMG110.TOGO (122), martakmg (123), mengmengmaliu (124), mizhg_us (125), mt19961020@163.com (126), Otecola (127), oyl54454 (128), palmdale (129), qiaolei (130), renttao (131), Rodoho (132), sabrina ladies (133), shiqinnaxie (134), simivalley (135), StarstruckPiercings (136), taowanwan (137), Tit is jewelry (138), tongyanxiaoyu (139), trenton (140), TropicalParadise (141), wuyuetian (142), xiaofandianpu (143), xinlihanlight (144), xiyoudrink (145), YINGDUOMILA (146), youyoutiandi3 (147), zhangmenyuan (148) and zm748788967 (149) added to case caption.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 10/4/2023. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction 42 is granted. Enter Order. The Clerk's Office is directed to unseal Plaintiff's Schedule A to the Complaint 3 and the Temporary Restraining Order 29. An in-person status hearing is set for 11/17/2023 at 10:00 AM. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 10/4/2023. Mailed notice.

SUMMONS Returned Executed by Believe Pursue LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A to the Complaint on 9/29/2023, answer due 10/20/2023.

(Exhibit Schedule A to Complaint)

ATTORNEY Appearance for Defendants BRRNOO (41), De Xing Yang Store (44), Jingzhi Trading Co., Ltd. (56), Wanyihong STORE (81), frysk974 (21), livest by Timothy Tiewei Wang

MOTION by Defendants BRRNOO (41), De Xing Yang Store (44), Jingzhi Trading Co., Ltd. (56), Wanyihong STORE (81), frysk974 (21), livest for extension of time to file answer regarding complaint, 1

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 48 before Honorable Sharon Johnson Coleman on 10/25/2023 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Defendants BRRNOO (41), De Xing Yang Store (44), Jingzhi Trading Co., Ltd. (56), Wanyihong STORE (81), frysk974 (21)'s unopposed motion for extension of time to answer or otherwise 48 is granted. Responsive pleading to be filed by 11/10/2023. No appearance necessary on 10/25/2023. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC re Defendant Nos. 1, 19, 20, 28, 29, 30, 31, 33, 55, and 58

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendants didi29455 (1), chihyupi (19), excellentsale004 (20), tablode (28), topoutlet2018 (29), xiyuanmio3 (30), ydanqing-0 (31), zheli254 (33), HuaShao LLC (55), and LINNAO Ltd (58) only. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC re Defendant Nos. 17, 18, 24, 43, 60, 65, 80, 84, and 132.

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendants 144mph-oz (17), 144mph-uk (18), kehuas-40 (24), CZ TRADE Co.Ltd (43), Mightlink (60), Rong Yun Co. Ltd. (65), Vinegarsun (80), xinhuadsh (84), and Rodoho (132) only. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC re Defendant Nos. 21, 41, 44, 56, and 81.

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendants frysk974 (21), BRRNOO (41), De Xing Yang Store (44), Jingzhi Trading Co., Ltd. (56), and Wanyihong STORE (81) only. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC re Defendant No. 69 (shenzhenshifanyilinshipinyouxiangongsi)

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendant shenzhenshifanyilinshipinyouxiangongsi (69) only. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Status hearing held on 11/17/2023. Counsel for plaintiff reported that 25 of the defendants have settled and counsel is in active settlement negotiations with a some of the remaining defendants. An in-person status hearing is set for 1/5/2024 at 10:00 AM. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC re Defendant No. 68 (shanghairongrandianzikejiyouxiangongsi)

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendant shanghairongrandianzikejiyouxiangongsi (68) only. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC of Defendant No. 68 (shenzhenshiweihanglingchuangwangluokejiyouxiangongsi)

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendant shenzhenshiweihanglingchuangwangluokejiyouxiangongsi (70) only. Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC of Defendant Nos. 122 (LOVEMG110.TOGO) and 123 (martakmg)

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendants LOVEMG110.TOGO (122) and martakmg (123) only. Mailed notice.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice.

NOTICE of Voluntary Dismissal by Believe Pursue LLC PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL OF CERTAIN DEFENDANTS

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendants Exercabest Fitness Co. Ltd (47) and JiangXLin (115) only. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Status hearing held on 1/5/2024. Defendants did not appear nor contact the Court. Counsel for plaintiff reported that still in negotiations with the remaining defendants. An in-person status hearing is set for 1/19/2024 at 10:00 AM. Mailed notice.

MOTION by Plaintiff Believe Pursue LLC for default judgment as to the Defaulting Defendants identified on the First Amended Schedule A

Memorandum in Support of Plaintiff's Motion for Entry of Default and Default Judgment

Declaration Declaration of Alisha Moriceau

Exhibit A - Email of Summons and Complaint to Defaulting Defendants

Exhibit B - Website

Exhibit C - First Amended Schedule A

Exhibit D - Iron Maiden Default Judgment

(Exhibit E - Breakdown of Amounts Restraints and Requested Profit Award)

NOTICE of Voluntary Dismissal by Believe Pursue LLC of Defendant No. 59 (MEZOOM)

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), this case is dismissed without prejudice as to defendant MEZOOM (59) only. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Status hearing held on 1/19/2024. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of default and default judgment 70 is granted. Default judgment is entered in favor of plaintiff and against the remaining defendants identified in Amended Schedule A. Enter Order. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 1/19/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order 74 of Defendant No. 110 (FUJIAN C-long Flly Co.,Ltd)

MOTION by Plaintiff Believe Pursue LLC for disbursement of funds - Return of Bond

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's motion for return of bond [76] is granted. Enter Order. Mailed notice.

DISBURSEMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 11/7/2024. Mailed notice.