2023-cv-14498

COMPLAINT filed by Converse Inc.; Filing fee $ 402, receipt number AILNDC-21186514.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Converse Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Converse Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Converse Inc.

Notice of Claims Involving Trademarks by Converse Inc.

ATTORNEY Appearance for Plaintiff Converse Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Converse Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Converse Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Converse Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MOTION by Plaintiff Converse Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Converse 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 Joe Pallett regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 3 - Parts 1-10 regarding declaration[14]

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 3 - Part 11-12 regarding declaration[14]

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

MEMORANDUM by Converse Inc. in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[17], motion for temporary restraining order[11], motion for leave to file[3] before Honorable John Robert Blakey on 10/11/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants Plaintiff's motions for leave to file under seal 3 and for electronic service of process 17. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 11. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 10/20/23. The 10/11/23 Notice of Motion date is stricken. Mailed notice

SEALED ORDER Signed by the Honorable John Robert Blakey on 10/6/2023. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $10,000 posted by Converse Inc. (Document not scanned.)

MOTION by Plaintiff Converse Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Converse Inc. in support of extension of time 24

(Declaration of Marcella D. Slay)

NOTICE of Motion by Marcella Deshonda Slay for presentment of extension of time 24 before Honorable John Robert Blakey on 10/18/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's ex parte motion 24 to extend the temporary restraining order entered 10/6/23 22. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 11/3/23. The 10/18/23 Notice of Motion date is stricken. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MOTION by Plaintiff Converse Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Converse 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 John Robert Blakey on 11/1/2023 at 11:00 AM.

(Exhibit A)

SUMMONS Returned Executed by Converse Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/27/2023, answer due 11/17/2023.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 28, this case is dismissed without prejudice as to Defendants (CoolCustomize 17), (funny and novelty design 24), (Great Tree One 25), (HEFEI GONGYINGXIANTOU SHANGMAO YOUXIANGONGSI 32), (HYPOCRUTE Shoes 35), (JieZunMan 38), (Lianhuicantaoshangmao 42), (LUMUBBY 48), (Pawnana 54), (Waluzs Store 68), (casualshoess20 88), (Qualityshoesstore 89), (yourtreasure1 90) and (Shiling shoe bag 107). Absent reinstatement within 270 days of the entry of this order, these defendants will be dismissed with prejudice without further order of the Court. Mailed notice

ATTORNEY Appearance for Defendants Obtaom shoes, Shirry, ALTOCIS, FINIWOR SHOES STORE, Povoger Shoes, ZGR Shoes by Timothy Tiewei Wang

ATTORNEY Appearance for Defendants ALTOCIS, FINIWOR SHOES STORE, Obtaom shoes, Povoger Shoes, Shirry, ZGR Shoes by Stevenson Moore

Notice of Appearance

MINUTE entry before the Honorable John Robert Blakey: Attorney Stevenson Moore's oral request to appear via telephone for the 11/1/2023 motion hearing is granted. Counsel shall call into 877-402-9753 and utilize participant code 9955840. 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

ATTORNEY Appearance for Defendants XUFU Trading Co., Ltd, Xuruihang Trading Co., Ltd by Stevenson Moore

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 11/1/2023. Plaintiff and Defense counsel for Defendants Obtaom Shoes, Shirry, ALTOCIS, FINIWOR SHOES STORE, Povoger Shoes, ZGR Shoes, XUFU Trading Co., LTd. and Xuruihang Trading Co., Ltd. appeared. All other Defendants failed to appear or otherwise objected in response to the TRO or Plaintiff's motion for entry of a preliminary injunction [29]. Accordingly, and based upon the same findings made in this Court's TRO [22], this Court finds that a preliminary injunction is appropriate and warranted, as well as unopposed and grants Plaintiff's motion for preliminary injunction [29]. Enter Preliminary Injunction Order. The Court directs the Clerk to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the Court's docket within three business days. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. By 12/5/23, Plaintiff shall 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. Alternatively, Plaintiff may file a motion for default judgment if appropriate. Counsel shall submit any order regarding asset restraint to the Court's Proposed Order in-box by close of business on 11/1/2023. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable John Robert Blakey on 11/1/2023. Mailed notice

NEW PARTIES: A1AS92OVQN7KPR, A1BG1ZVT2T35VK, A223665dd, A2VDRJXHZ3IKGA, ABZHRYICIRGXX, Adokoo, ailong dianzi, ALTOCIS SHOES, annengvas, ANQILA-DESIGN, ANTLULU SHOES, Bestshoptheday, Caspian Network, Cen.Han Store, CHEN LIN123, CJDSWYXGS, Cull4U, Dig Treasure, fasiter, FINIWOR SHOES STORE, Firehors, FRACORA director, Grosun, gujia shoes, GUO XU ZE, hai kou long hua qi mu han bai huo shang hang, haifengll, hash bubbie, hongchenzhao, hongnabaihuoshanghang, IFANS, JianYunRiYongBaiHuoJingXiaoBu, JOSINY Fashion, kufeiti shoes, Lafreddy INC, LIU SHENG HAO, LiujiaoSHOP, LIUYUNShop, long yan shi yong ding qu ping zhou dian zi shang, LU AN YONG, Magic beans store, Ms Stunner, NIFU, NORNETEK, Obtaom shoes, PF-Shoes, pingweistore, Povoger Shoes, putianshilichengqulvshishenshangmaoyouxiangongs, SHCRTK, Shengyi Shoes, STAR MOCHI, Suopaint US, SusannaXiao, TASEKI STORE, The Sneaker Land, veinwira, VXDECAL, WenJing ShangMao, WENRJIN, wuyuanbin, Xianglan, xianyouxianlichengyiqingfushidian, Xiaosuitheone, xirunlian, YANGNA1, YangXiBoshop, Yaoguo-ltd, YEEDOIDO Shops, Yjzhucheng, YuanZhangGui, YUXISHOP, ZGR director, ZHANG YONG LING, zhengliheng08, zhonyimaoyiyouxiangongsi, ZiFuBaiHuoDian, endexinele, ever-jo, tigne88, 6.17059E+12, Augustus Crown of Shield, BeibeiBear, BOCHEN Gtop quality, Feiss, Haimengbao baby, HERYUM For Kids Shoes, hhkaimi, Jiuzheng computer accessories, liuyilin, Margaret, MENGDA, OPOEE children shoes, SOWOH, XRH shoes, xuanxuan Childrens shoes, Ironkoi, JENN ARDOR, JUND Little Store, Kikuu, Nightingale, XDASG, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd and Zenicham added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MOTION by Defendants ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd, ZGR director 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[42] before Honorable John Robert Blakey on 11/22/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the notices of voluntary dismissal 40, 41, the Court hereby dismisses this case without prejudice as to the following Defendants: Annengvas (No. 9); FRACORA director (No. 23); Grosun (No. 26); gujia shoes (No. 27); hash bubbie (No. 31); kufeiti shoes (No. 40); NIFU (No. 51); Obtaom shoes (No. 53); Shengyi Shoes (No. 60); casualshoess20 (No. 88); Qualityshoesstore (No. 89); yourtreasure1 (No. 90); Adokoo (No. 6); The Sneaker Land (No. 65); and Ironkoi (No. 111). Absent reinstatement by 8/16/23, the dismissal as to these Defendants shall automatically convert to a dismissal with prejudice. Additionally, the Court grants the unopposed motion to extend time filed by Defendants ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, ZGR director, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd 42 and strikes the 11/22/23 Notice of Motion date. These Defendants shall respond to the complaint by 12/8/23. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Based upon the filings of the notices of voluntary dismissal 40 and 41, Defendants (Annengvas 9), (FRACORA director 23), (Grosun 26), (gujia shoes 27), (hash bubbie 31), (kufeiti shoes 40), (NIFU 51), (Obtaom shoes 53), (Shengyi Shoes 60), (casualshoess20 88), (Qualityshoesstore 89), (yourtreasure1 90), (Adokoo 6), (The Sneaker Land 65) and (Ironkoi 111) are dismissed without prejudice with leave to reinstate within 270 days of the entry of this order. Absent reinstatement, these defendants will be dismissed with prejudice. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the filings of the notice of voluntary dismissal 46 the Court dismisses this case without prejudice to the following Defendants: A223665dd (No. 3); ABZHRYICIRGXX (No. 5); NORNETEK (No. 52); PF-Shoes (No. 55); STAR MOCHI (No. 61); Suopaint US (No. 62); BOCHEN Gtop quality (No. 97); Haimengbao baby (No. 99); Hhkaimi (No. 101); OPOEE children shoes (No. 106); xuanxuan Childrens shoes (No. 110); Nightingale (No. 115); and Zenicham (No. 119). Absent reinstatement by 8/16/24, the dismissal as to these Defendants shall automatically convert to a dismissal with prejudice. Mailed notice (Main Document 47 replaced on 11/21/2023 to correct reinstatement date). Modified on 11/21/2023.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

STATUS Report per [38] by Converse Inc.

MINUTE entry before the Honorable John Robert Blakey: Based upon the Notice of Voluntary Dismissal [48], the Court hereby dismisses this case without prejudice as to the following Defendants: ANTLULU SHOES (No. 11); Cull4U (No. 18); Firehors (No. 22); Lafreddy INC (No. 41); SHCRTK (No. 59); endexinele (No. 91); Feiss (No. 98); JUND Little Store (No. 113); and XDASG (No. 116). Absent reinstatement by 9/6/24, the dismissal as to these Defendants shall automatically convert to a dismissal with prejudice. Additionally, as discussed in court on 11/1/23, the parties have now submitted a proposed order governing the agreed asset restraint as to Defendants ALTOCIS SHOES (No. 8), FINIWOR SHOES STORE (No. 21), Povoger Shoes (No. 57), ZGR director (No. 83), XUFU Trading Co., Ltd (No. 117), and Xuruihang Trading Co., Ltd (No. 118). Enter Agreed Order. Mailed notice

AGREED ASSET RESTRAINT ORDER FORDEFENDANT NOS. 8, 21, 57, 83, 117, AND 118 Signed by the Honorable John Robert Blakey on 12/6/2023. Mailed notice

MOTION by Defendants ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd, ZGR director 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[52] before Honorable John Robert Blakey on 12/13/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants the motion to extend time filed by Defendants ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, ZGR director, XUFU Trading Co.,Ltd, and Xuruihang Trading Co., Ltd [52] and strikes the 12/13/23 Notice of Motion date. These Defendants shall respond to the complaint by 12/22/23. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

ANSWER to Complaint with Jury Demand by ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd, ZGR director

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ALTOCIS SHOES, FINIWOR SHOES STORE, Povoger Shoes, XUFU Trading Co.,Ltd, Xuruihang Trading Co.,Ltd, ZGR director

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's notices of voluntary dismissal; [55], [56], the Court hereby dismisses this case without prejudice as Defendants Ms Stunner (No. 50) and IFANS (No. 36). Absent reinstatement by 9/20/24, this dismissal shall automatically convert to a dismissal with prejudice. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

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.

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's notice of voluntary dismissal 60, the Court hereby dismisses this case without prejudice under Rule 41(a) as Defendant Caspian Network (No. 13). Absent reinstatement by 9/27/24, this dismissal shall automatically convert to a dismissal with prejudice. The parties shall file a status report by 1/30/24, using the model template set forth in this Court's standing order regarding Initial (or Reassignment) Status Conferences. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to a Certain Defendant

MOTION by Plaintiff Converse Inc. for entry of default, MOTION by Plaintiff Converse Inc. for default judgment as to all Defendants with the exception of certain Defendants

Exhibit A

MEMORANDUM by Converse Inc. in support of motion for entry of default, motion for default judgment, [64]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[65]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, [64] before Honorable John Robert Blakey on 1/17/2024 at 11:00 AM.

Exhibit A

MINUTE entry before the Honorable John Robert Blakey: The Court strikes the 1/17/24 Notice of Motion date and resets the hearing on Plaintiff's motion for default and default judgment 64 to 1/24/24 at 11:00 a.m. in Courtroom 1203. Mailed notice

NOTICE of Voluntary Dismissal by Converse Inc. as to Certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the notice of voluntary dismissal [69], this case is hereby dismissed without prejudice as to Defendants Feiss (No. 98) and MENGDA (No. 105). Absent reinstatement by 10/22/24, this dismissal shall automatically convert to a dismissal with prejudice. Mailed notice

ATTORNEY Appearance for Plaintiff Converse Inc. by Justin Tyler Joseph

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 1/24/2024. The Court grants Plaintiff's motion for entry of default and default judgment as to the defendants identified the Schedule A, with the exception of defendants ALTOCIS SHOES (Def. No. 8), FINIWOR SHOES STORE (Def. No. 21), Povoger Shoes (Def. No. 57), ZGR director (Def. No. 83), XUFU Trading Co., Ltd (Def. No. 117), and Xuruihang Trading Co., Ltd (Def. No. 118) [64]. Enter Default Judgment Order. Status hearing set for 2/23/2024 at 11:00 a.m. in Courtroom 1203. Mailed notice.

DEFAULT JUDGMENT ORDER. Signed by the Honorable John Robert Blakey on 1/24/2024. Mailed notice.

MINUTE entry before the Honorable John Robert Blakey: On the Court's own motion and by agreement of counsel, status hearing previously set for 2/23/2024 is reset for 2/27/2024 at 11:00 a.m. in Courtroom 1719. Mailed notice

STATUS Report per 62 by Converse Inc.

MINUTE entry before the Honorable John Robert Blakey: Based upon the representations in the parties' 1/30/24 status report 75, the Court strikes the 2/27/24 status hearing date and orders the parties to file an updated status report by 3/29/24 proposing next steps to advance the case. Mailed notice

STIPULATION of Dismissal Joint

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the joint stipulation of dismissal 77, this case is now dismissed. Civil case terminated. Mailed notice