2023-cv-04835

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 402, receipt number AILNDC-20864337.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

Notice of Claims involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Berel Yonathan Lakovitsky

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.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment.

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Adraea M. Brown regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 3 - Parts 1-6 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc.for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for miscellaneous relief 16

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

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 16, motion for temporary restraining order 11, motion for leave to file 3 before Honorable Elaine E. Bucklo on 8/2/2023 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 3 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 11 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 16 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 8/16/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 8/9/2023. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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. The case is set for a status hearing on 9/18/2023 at 9:45 a.m. (to track the case only, no appearance is required). By 9/11/2023 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 8/2/2023. Mailed notice.

SURETY BOND in the amount of $10,000 posted by Harley-Davidson Motor Company, Inc. (Document not scanned.)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of extension of time 23

(Declaration of Marcella D. Slay)

NOTICE of Motion by Marcella Deshonda Slay for presentment of extension of time 23 before Honorable Elaine E. Bucklo on 8/16/2023 at 09:45 AM.

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

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 23 is granted to 8/30/2023. Mailed notice.

MAILED trademark report with certified copy of minute order dated 8/14/2023 to Patent Trademark Office, Alexandria VA.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction 29

Declaration of Marcella D. Slay

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 29 before Honorable Elaine E. Bucklo on 8/30/2023 at 09:45 AM.

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/25/2023, answer due 9/15/2023.

Declaration of Berel Lakovitsky

(Exhibit A)

STATUS Report per 20 by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Trevor Christian Talhami

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction as to certain defendants [29] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Adraea M. Brown [15], and the TRO [21]. Pursuant to the status report, plaintiff reports active settlement discussions with several defendants. Plaintiff will move for default judgment at a later date where appropriate. Status hearing is reset for 10/18/2023 at 9:45 a.m. (to track the case only, no appearance is required). The plaintiff shall file a written status report by 10/11/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 9/18/2023. Mailed notice.

NEW PARTIES: Dongguan Leimisi Metal Jewelry Co., Ltd., Shenzhen Bao'an Atila Jewelry Factory, Shenzhen Mujing Trading Co., Ltd., Shop1102709454 Store, SunshineCraft Store, The Box Store, TTqpee Store, Wholesale Dropshipping T-shirt Factory From China Store, YMT Car Accessories Store, A124F5EG4WTPPD, A1AAVCILE0N957, A2BESHG1NBZ8E3, A2SITZULC4VEF1, A34Y6QU59S1STI, A3D67M4ECPCMGB, aixiugankejiyiuxiangongsi, AMTCQ3MSPYPJS, AnQingWuMeiShangMaoShangHang, Beautt shop, CaiHong Clothing Store, chaoping8680, ChenChengGuo, chunzhenbaihuodian, ChuSiWei, cym115, dengkouxianlongshenghezhentaofanbaihuochaoshi, fengjinping youth, fhngo, FochunChang, GFF-Shops, guangzhouyuyishangmaoyouxiangongsi1, HeFeiKouShuoEWeiShangMaoYouXianGongSi, HFABSM, HJFDNHJNDF, hu die hua, JingShiXuanShangMaoYouXianGongSi, kldhgh, KunMingT, Lilynan, liu1233, liudaxiang-shop, LIYINAN, luwang-shop, Machang123, NANAZE(gaowohouguozifu), Nbcdds, Nhsats, Noaross Custom Flag Factory, peijing, pin zhi sheng huo ti yan guan, Pretties Direct, QinHongTong, qixingguanquyunshibaihuodian, Rankerxz, richudongfangwoailin, srefgs, taotiedianzi, Tegoge, uiopiplu, WUCLI, xiemantaoHBGBFA564, Xu Tingting store, YUNAZE, zhanruyi, zxx115, ZXXXX1, HUAYOUSHANGMAO, bailu11, bestlvgo, cheng13358511013, dingdongq, huangk833, ksld, lulues, mcqueen_store, snatti, vzu3, yuliguo2, bamu06_55, boyangwc, kojfso, weiijij, yidingyaofacai, Auto Keys House, Shangyu Crafts Factory, YIZHUODY, asdaghdjfggtr, DSVIE FASHION, liangliangyingying, ouxianqi1986, sunsunxinxin, tanyaportillo, Zejuanshop and zhoucong8953 added to case caption.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

STATUS Report per [35] by Harley-Davidson Motor Company, Inc.

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/13/2023, answer due 11/3/2023.

Declaration of Marcella D. Slay

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with various defendants. Status hearing is reset for 11/30/2023 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 11/23/2023. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to a Certain Defendant

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, [43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, [43] before Honorable Elaine E. Bucklo on 11/16/2023 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment [43] against all remaining defendants is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Harley-Davidson Motor Company, Inc. or its counsel Greer Burns & Crain Ltd. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 11/15/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding order 48 in the amount of $250,000 as to certain defendant

NOTICE of Correction regarding document number 27.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MAILED trademark report with certified copy of minute order dated 11/15/2023 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 48 in the amount of $250,000 as to certain defendants

NOTICE of Removal of Material from the Custody of the Clerk's Office by John Summerfield (Received for docketing 4/5/2024)

FULL SATISFACTION of Judgment regarding order 48 in the amount of $250,000 as to certain defendant