2023-cv-15542

COMPLAINT filed by Levi Strauss & Co.; Filing fee $ 402, receipt number AILNDC-21285368.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Levi Strauss & Co. Schedule A regarding complaint[1]

MOTION by Plaintiff Levi Strauss & Co. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Levi Strauss & Co.

Notice of Claims Involving Trademarks by Levi Strauss & Co.

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Levi Strauss & Co. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Levi Strauss & Co. in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Zachary Toczynski regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Levi Strauss & Co. Exhibit 2 - Parts 1-4 regarding declaration 16

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

(Exhibit 2-4)

MOTION by Plaintiff Levi Strauss & Co. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Levi Strauss & Co. in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 18, motion for temporary restraining order 13 before Honorable Manish S. Shah on 11/8/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [13] [18] are granted, and no appearance on the motions is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 11/6/2023.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (mek,)

SURETY BOND in the amount of $50,000 posted by Levi Strauss & Co. (Document not scanned.)

MOTION by Plaintiff Levi Strauss & Co. for extension of time of Temporary Restraining Order

MEMORANDUM by Levi Strauss & Co. in support of extension of time[24]

Declaration of Jake M. Christensen

NOTICE of Motion by Jake Michael Christensen for presentment of extension of time[24] before Honorable Manish S. Shah on 11/16/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 24 is granted, and no appearance on the motion is necessary. The TRO is extended to 12/4/23. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MOTION by Plaintiff Levi Strauss & Co. for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Levi Strauss & Co. in support of motion for preliminary injunction 30

Declaration of Jake M. Christensen

(Exhibit 1)

NOTICE of Motion by Jake Michael Christensen for presentment of motion for preliminary injunction 30 before Honorable Manish S. Shah on 12/6/2023 at 09:45 AM.

(Exhibit A)

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Jake Michael Christensen

SUMMONS Returned Executed by Levi Strauss & Co. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/30/2023, answer due 12/21/2023.

Declaration of Quinn B. Guillermo

(Exhibit A)

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Rachel S Miller

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [30] is granted. Enter Preliminary Injunction Order. The Clerk is directed 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. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 12/6/2023. Notices mailed.

NEW PARTIES: Chengdu. Cocolor. Co., Ltd, Guangzhou SLKD Technology Development Co., LTD, Haining Yanguan Jianbu Leather Slippers Factory, Huizhou Taiyu Trading Co., Ltd., Quanzhou Walson Imp & Exp Co., Ltd., Wenling Jinbo Trade Co., Ltd., Wenzhou Xintong Trading Co., Ltd., Xiamen Bristter Sports Products Co., Ltd., Xiamen Jingyuan Trade Co., Ltd., 1July Store, 674245 Store, AAAS Store, BKQU Fashion Store, BOGUO369 Store, Cici clothing Store, CINESSD JiaShi Store Store, CYGJ Store, EAnvog Franchise Store, EKMT Store, GengZi Mouse Store, Glamorous Wardrobe Store, Global 2021 Store, Global dropshipping factory 01 Store, GXMGST888 Store, IVCBSGEE Shoes Store, JIFALZS Official Store, jiuyaoda Store, Ju Re Store, L&L T-shirt Store, Ladies Sandals Store, luckhuizhao Store, LUXXETON Chinese Store, Lynchin Footwear Store, M M Tidal Current Store, Maihuohuo027 Store, Mbbcar Bedrock Store, meiliang Store, Miaoguan Official Store, MIOCKY Store, MOMOK Store, OLOMM DROP SHIP Store, Pink Celebrity Shoe Store, Rtc66 Store, SBIP global shop Store, Shop1100298218 Store, Shop1100370549 Store, FLYGUIYANGMOT0, kaidilake-us, SuperDuo, tengzhoushixinsenlinbaihuoshangmaoyouxiangongsi, TianJinFuZhuangDian, a31415929, A5050, Babiq05, best1888sinacom, bigdesigner Store, bin66, bingsyuning Store, c514769921, cai17553712621, cailie870120, chaopai01, chaorenvip2, chaorenvip3, chromeheart, chxm1, chzz1, datoudingshangmao, designer_clothess, designer07, dhb5, dhy4, dlstyleclothes, E3zg, Estas, falmouth, fashionicon001, fjxp6, fjxp8, G3nr, Gn5r, Gou03, haifengmaoyi1 Store, happy-angelet1 Store, highend02, Hui06, flying-eagle-shop, hengkui26, huihuitradingho0, yuxi521, zongchuang-de, AIOPESON, Chengmei Clothing, EDAW, Jasio, All- in Lucky store, liao517909, mengyang55089 and wmmmmm added to case caption.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

SUMMONS Returned Executed by Levi Strauss & Co. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/12/2023, answer due 1/2/2024.

Declaration of Quinn B. Guillermo

Exhibit A

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

MOTION by Attorney Jake M. Christensen to withdraw as attorney for Levi Strauss & Co. No party information provided

NOTICE of Motion by Justin R. Gaudio for presentment of motion to withdraw as attorney 41 before Honorable Manish S. Shah on 1/3/2024 at 09:45 AM.

NOTICE of Voluntary Dismissal by Levi Strauss & Co. as to certain defendant

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Berel Yonathan Lakovitsky

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 Manish S. Shah: The motion to withdraw as attorney 41 is granted, and no appearance is necessary. Attorney Christensen's appearance is terminated

MOTION by Plaintiff Levi Strauss & Co. for entry of default as to all Defendants, MOTION by Plaintiff Levi Strauss & Co. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Levi Strauss & Co. in support of motion for entry of default, motion for default judgment[47]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

NOTICE of Motion by Berel Yonathan Lakovitsky for presentment of motion for entry of default, motion for default judgment[47] before Honorable Manish S. Shah on 1/9/2024 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment [47] is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 1/9/2024. Notices mailed.

FULL SATISFACTION of Judgment regarding order 52 as to certain defendant

FULL SATISFACTION of Judgment regarding order 52 as to certain defendant

NOTICE of withdrawal of surety bond 27 by John Summerfield (Received at the Intake Counter on 3/29/2024)