2023-cv-15217

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 402, receipt number AILNDC-21248037.

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

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 2).

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.

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 Trevor Christian Talhami

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 1-5 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

(Exhibit 3-5)

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 leave to file 3, motion for temporary restraining order 11 before Honorable Sara L. Ellis on 10/31/2023 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for leave to file under seal [3], for electronic service of process [16], and for entry of a temporary restraining order [11]. The Court sets a status date for 11/14/2023 at 9:45 AM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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 Sara L. Ellis on 10/30/2023

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Sara L. Ellis on 10/30/2023. Mailed notice.

NOTICE of Correction regarding entry 22.

CIVIL BOND in the amount of $ 10,000 posted by Harley-Davidson Motor Company, Inc.

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

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 25

Declaration of Marcella D. Slay

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 25 before Honorable Sara L. Ellis on 11/14/2023 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/9/2023, answer due 11/30/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

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

MINUTE entry before the Honorable Sara L. Ellis: Telephone conference held on 11/14/2023 and continued to 12/14/2023 at 1:30 PM. The Court grants Plaintiff's motion for preliminary injunction [25]. The Law Firm of Greer, Burns & Crain Ltd. 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 located at www.ilnd.uscourts.gov/instructions. Plaintiff should file any motion for default and entry of default judgment and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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

NEW PARTIES: Shop1102855777 Store, Shop1102858924 Store, Shop1102890225 Store, Shop1103078661 Store, Shop1103132875 Store, Stainless Metal World Store, 1jingweidong1, A1YI36G1K858PX, A1YI5QKSE5JSWB, A39B3AQSWLO9RN, A3LGM0UQOG7RZW, agenyingshangmaocheng, COOLSTEELANDBEYOND, DECHENDIANZI, Deliverywithin7-12days10086, DingDingUS home, Dmphuong939, E.BESTSHOP, guangzhouhaifashangmaoyouxiangongsi, H.Y.Shopp, haikouqiongshanyuwuhuibaihuodian, HMLOPX 5-13 days delivery, hongshanqushibabaihuodian, HTLEATHER, Huitan Trading Company Limited, jiarong5, Jie cheng Technology, jinzhoushishanariyongbaihuojingxiaodian, JUN YI MAO YI, KeQiuYa, Kirolly, LANGGUAN, LGEEYS, mengdiebaihuodian, MGSTSN1, Monaca, MUSAXI SuperStore, Pro Flag Depart (ENMOONVagairKasflag QiQ, putianshichengxiangqupanminchanshangmaoyouxiangon, qingrongbaihuo, qiyuewangluo, ShanShan BaiHuo, SXZ Shop, Teelaka Store, Tors, xuting store, Yaleand, yingyingbaihuosahnghang, YISHIFZU-US, YuCeCommerce, YYL-SHOP, enshishirugongsha0, haoduodan2, jiayi_patches_world2, kuaidianfacai, mypet01, sqmc_motoshop, xiaolumama, yimutrade, zeisaijim28, chole kids, Jin Heng, dayi energe, Deepstone, Fnochy Co.Ltd, Liangchou, yichen, Age Elves Store, ccgxxdurs, fuhengfu4284, lvmeahlke, pdqgcipzm, qsphoqoyr and RobleSport added to case caption.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Sara L. Ellis on 11/14/2023:Mailed notice

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/21/2023, answer due 12/12/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

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

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to Extend the Deadline to File its Motion for Entry of Default and Default Judgment

Exhibit A

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for miscellaneous relief[33] before Honorable Sara L. Ellis on 12/14/2023 at 01:30 PM.

Exhibit A

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

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 with the exception of certain Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, [36]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[37]

Exhibit 1

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. to approve consent judgment as to Defendant Nos. 64 and 67

Exhibit A

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion to approve consent judgment[39], motion for entry of default, motion for default judgment, [36] before Honorable Sara L. Ellis on 12/19/2023 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for extension of time [33]. The Court strikes the status date set for 12/14/2023 and resets it to 12/19/2023 at 9:45 AM. Plaintiff should file any motion for default judgment and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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 Sara L. Ellis: Telephone conference held on 12/19/2023. The Court grants Plaintiff's motion for entry of default and default judgment [36]. The Court enters judgment in favor of Plaintiff and against Defendants identified in amended Schedule A. The Court grants Plaintiff's motion for approval of consent judgment as to Defendants Nos. 64 and 67 [39]. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 12/20/2023:Mailed notice

FULL SATISFACTION of Judgment regarding entered judgment 43 in the amount of $100,000 as to certain defendants

CONSENT JUDGMENT. Signed by the Honorable Sara L. Ellis on 12/19/2023:Mailed notice

MAILED trademark closing report with certified copies of orders dated 12/19/2023 to Patent Trademark Office, Alexandria VA.

NOTICE of Removal of Material from the Custody of the Clerk's Office [24]. (Received at the Intake Counter on 07/25/24.)