2023-cv-04654

COMPLAINT filed by Skechers U.S.A., Inc. II; Filing fee $ 402, receipt number AILNDC-20843802.

Exhibit 1

(Exhibit 2)

SEALED DOCUMENT by Plaintiff Skechers U.S.A., Inc. II Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Yanling Jiang

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Yi Bu

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Adam Grodman

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Skechers U.S.A., Inc. II by Monica Rita Martin

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Skechers U.S.A., Inc. II

CASE ASSIGNED to the Honorable Andrea R. Wood. 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.

MOTION by Plaintiff Skechers U.S.A., Inc. II for leave to file under seal

MOTION by Plaintiff Skechers U.S.A., Inc. II for leave to file excess pages

MEMORANDUM in support of 13 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of of Keith A. Vogt's declaration

Declaration of Marshall A. Lerner

(Exhibit 1, of Marshall A. Lerner's declaration)

SEALED EXHIBIT by Plaintiff Skechers U.S.A., Inc. II Sealed Exhibit 2, Declaration of Marshall A. Lerner regarding memorandum in support of motion, 14

(Exhibit 2-1)

ENTERED IN ERROR Modified on 7/21/2023.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 11, motion to exceed page limitation 12, and ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 13 are set for a telephonic motion hearing on 7/26/2023 at 10:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

SEALED DOCUMENT by Plaintiff Skechers U.S.A., Inc. II Supplemental Evidence to the Sealed Exhibit 2, Declaration of Marshall A. Lerner 15

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 7/26/2023. Plaintiff is directed to make a supplemental submission in support of its motion for an ex parte TRO by 7/31/2023. Motions for leave to file excess pages 12 and under seal 11 are granted. Ex Parte Motion for relief 11 is taken under advisement. Telephone conference is set for 8/10/2023 at 9:45 a.m. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED DOCUMENT by Plaintiff Skechers U.S.A., Inc. II [CORRECTED] Schedule A to Complaint 1 and Schedule A to Complaint 2

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/10/2023. For the reasons stated on the record, Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 13 is granted. Enter Sealed Temporary Restraining Order. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 8/10/2023 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 8/24/2023 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 8/10/2023.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations d/b/a The Domain Names Identified on Schedule A

SURETY BOND in the amount of $ 10,000 posted by Skechers U.S.A., Inc. II. (Document not Scanned)

MOTION by Plaintiff Skechers U.S.A., Inc. II for preliminary injunction

ATTORNEY Appearance for Defendant The Partnerships and Unincorporated Associations d/b/a The Domain Names Identified on Schedule A by Gary Zhao appearance for wycddshop.com

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 8/24/2023. Counsel for Defendant No. 72, wycddshop.com, appeared on the call. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 25 is granted, with the exception of Defendant wycddshop.com, which has appeared through counsel, desires to oppose the entry of a preliminary injunction against it, and requires additional time to do so. Enter Preliminary Injunction Order. The Temporary Restraining Order will remain in effect as to Defendant wycddshop.com pending the resolution of the preliminary injunction motion as to it. By 8/29/2023, Plaintiff and Defendant wycddshop.com shall meet and confer and file a joint status report setting forth whether the parties intend to proceed with a contested preliminary injunction hearing and, if not, whether the parties have reached a negotiated resolution. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint 2, 21 ; (2) Exhibit 2, Declaration of Marshall A. Lerner 15 ; (3) supplemental evidence to Exhibit 2 19 ; and (4) the sealed temporary restraining order 23. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic motion hearing set for 8/31/2023 at 11:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 8/24/2023. Mailed notice

NEW PARTIES: buty-skechers.com, discountskechers.com, fafashopping.vip, fioutlets.com, footwearoutet.shop, irskechers.com, mxoutletonline.com, nearestskechersstore.com, onlinesprots.shop, pantofi-skechers.com, skecheoutletbest.com, skecher-outlet.com, skechersarbaratas.com, skechersayakkabi.com, skechersbogota.com, skechersboltbudapest.com, skechersboltokbudapest.com, skechers--canada.com and skecherscipoboltok.org added to case caption.

NEW PARTIES: skecherscipohu.com [cipoakcio.co], skechers-cipok.com, skechersegyptonline.com, skechersfactory.shop, skechersfactorysoutlet.com, skechers-france.com, skechershronline.com, skechershrwebshop.com, skechersinturkiye.com, skechers-ireland.com, skechersistanbul.com, skechers-istanbul.com, skechers-it.shop, skechersksaonline.com, skecherslojaportugal.com, skechersmexico-mx.com, skechersnzoutlets.com, skechers-online.com, skechersonlinejapan.com, skechers---outlet.com, skechersoutletfactoryus.com, skechersoutletmall.com, skecherssalesouthafrica.com, skechersshoesksa.com, skechersshoeuae.com, skechersshopstore.com, skecherssingapore.net, skechersskosalg-norge.com, skechersstoreireland.com, skechersszapatos.com, skechersuaeonline.com, skechersuaeonlinestores.com, skechersuaeoutlet.com, skechersuomiale.com, skechers-usa.us, skechersusonlineshop.com, skecherswebshopbudapest.com, skecherturkiye.com, skecheusoutlet.com, skechsaleonline.com and skecronline.shop added to case caption.

NEW PARTIES: skeoutlet.store, skephshoes.shop, skesneakers.shop, skesports.shop, skoskechers.com, skrooutlets.com, skxboot.com, tenisskecherspt.com, ukskechersoutlet.com, uniqueoi.com, whiteplainsplainsmen.com, wycddshop.com and zasmfashion.shop added to case caption.

STATUS Report Pursuant to Minute Entry Order 30 by Skechers U.S.A., Inc. II

MINUTE entry before the Honorable Andrea R. Wood: Due to a change in the Court's schedule, telephonic motion hearing set for 8/31/2023 is stricken and reset for 8/31/2023 at 9:45 AM. (TIME CHANGE ONLY). To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/31/2023. Plaintiff and Defendant wycddshop.com confirm that they do not require a preliminary injunction hearing and instead request additional time to work towards a negotiated resolution. By the agreement of the parties, the Temporary Restraining Order will remain in effect as to Defendant wycddshop.com pending the resolution of the preliminary injunction motion as to it. Telephonic status hearing set for 10/4/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff Skechers U.S.A., Inc. II for default judgment as to The Defendants Identified In First Amended Schedule A

(Exhibit 1)

MEMORANDUM by Skechers U.S.A., Inc. II in support of motion for default judgment 35

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 35 before Honorable Andrea R. Wood on 10/4/2023 at 09:15 AM.

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 10/4/2023. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against the Defendants identified in First Amended Schedule A 35 is granted, with the exception of Defendant wycddshop.com. Enter Default Judgment Order. Defendant wycddshop.com's oral motion for an extension to file its answer to Plaintiff's complaint is granted. Defendant wycddshop.com shall file its answer by 11/6/2023. Telephonic status hearing set for 11/14/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

Answer and affirmative defenses ANSWER to Complaint by wycddshop.com

MINUTE entry before the Honorable Andrea R. Wood: Due to the Court's trial schedule, telephonic status hearing set for 11/14/2023 is stricken and reset for 11/14/2023 at 12:30 PM. (TIME CHANGE ONLY). To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 11/14/2023 and continued to 12/12/2023 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 11/14/2023. Mailed notice

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 72 wycddshop.com

MINUTE entry before the Honorable Andrea R. Wood: The remaining parties having filed a stipulation of dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii) 43, this case is dismissed with prejudice and with each party to bear its own attorneys' fees and costs. All pending hearing dates and motions are stricken. Civil case terminated. Mailed notice