2023-cv-16073

COMPLAINT filed by Nike, Inc.; Filing fee $ 402, receipt number AILNDC-21341837.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Nike, Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Nike, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Nike, Inc.

Notice of Claims Involving Trademarks by Nike, Inc.

ATTORNEY Appearance for Plaintiff Nike, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Nike, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Nike, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Nike, Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Young B. Kim. 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 Nike, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Nike, 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 Nike, Inc. Exhibit 3 - Parts 1-10 regarding declaration[14]

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

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

MEMORANDUM by Nike, 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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [11] is granted. Plaintiff's motions for leave to file under seal [3] and for electronic service of process [17] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 11/27/2023. Mailed notice

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

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

MEMORANDUM by Nike, Inc. in support of extension of time[24]

Declaration of Marcella D. Slay

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 12/4/2023. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order [24] is granted. Enter order. Mailed notice

SURETY BOND in the amount of $ 119,000 posted by Nike, Inc. (Document not imaged)

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 36 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 65 and 66 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [31] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 77 and 81 are dismissed from this case. Mailed notice

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

MOTION by Plaintiff Nike, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[34]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/20/2023, answer due 1/10/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [33] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 82 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [16] is taken under advisement. Any objection or response is due before 12/26/23. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before December 26, 2023. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, text entry, 39

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 37 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 79 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [22] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 1/3/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 12/26/2023. Mailed notice

NEW PARTIES: GUOCHENXY Co., Ltd., Haikou Bengangxiao Trading Co., LTD, Heng Can Trade, jianbo shop, Jordan1-us, Jordan1-usa, kunmingmichoukejiyouxiangongsi, LiaoShuangEXiaoDian, liyongjj, LMQ SHOP, LOV ANNY, Love-house, Lufeng Puddle Star E-commerce Co., lufenghuaerliangdianzishangwuyouxiangongsi, MATTAY SKIN LLC., MOMOEU, nananshimeilinlibinxiedian, ngyishangmaoyouxiarbe, OTTINA, ouyifuwu, PingShangLong, POIHIDE, PUTIANSHICHENGXIANGQUJIAYUNFEIMAOYIYOUXIANGONGSI, qiaozixuan, qionghaihuanyeshangmaoyouxiangongsi, rain language, RINVEKA US, Rozdic Cool Kitchen Supplies, Topaz Brand Shop, Urbango, UUSSAAA, Wangjie DrugStore, WangShuChengXiaoDian, weifangqiguangwangluokejiyouxiangongsi, weilinbaihuoshanghang, WINEMOONUS, xinzhijianvzhuangyouxiangongsi, XuYueDongxiaodian, Xzyden, YangYanTaoShangMaoYouXianGongSi, zhangfeng26, zhuxixianhancanbaihuodian, Zowucpr, Ajsneakero, allshoes668, aq18895988588, balenciagashoes01, boock, brand_sport_leading, cbdshops, customshoes_th, dzsmshoes, esport_store, exclusivesunglasses, firstquality1, Foamrunner, gold_shopping_store, hpd853, huafei09, jaskicks, jin03, liancheng07, mens_luxury_shoes, mens_sneakers_shoes, affordableitems2022, bbstone7, defade-mabo, dian3-97, lulusneaker888, meiyunliuliu, naiyuan21, oursneaker88, streetmodelshoes, wowokick, Active Pro, Clearly is unripe brightness, Fairy bubble children shoes, Goodshoes, Haosen sports shoes franchise, HYFFma, QVXKD Kids Shoes, DAJIDALI, JJ tiger, LVQIXINXIKEJI, ajshijia123, Alcalina, Authentic Shoppe 2021, Brandon D Eldredge, CATHERINEMILOSCIAA, Chalecos AntiBalas Under, Cheap items for you, chenhongsheng2134, chenjunhao6799, Commerce JB Store, Cory W Bitne, Cxinying, DAICHENGWEN, ds.akhdkh, erty kj mgfaq, fanqingxuan4983, gaoxiaoli9360, gffdgfgfv, Halobigbang, HHJC.fashion, IFE International, Ilovemyjobbuy, lixiaona2874, luosiniu9101, lushuang6204, luweiyan3112, magnusjames, MariaKI, MiTangBANGYUNsM and Necesito Gallo added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

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 J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 44 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 12 and 28 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 47 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant number 17 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Nike, Inc. as to Certain Defendants

MOTION by Plaintiff Nike, Inc. for entry of default as to all Defendants, MOTION by Plaintiff Nike, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[50]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[51]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [49] and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 3 and 39 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [50] is taken under advisement. Any objections or responses are due by 1/29/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 1/19/24. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, set motion and R&R deadlines/hearings, [54]

Exhibit A

Exhibit B

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 56 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 89 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 58 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 22 and 29 are dismissed from this case. Mailed notice

MOTION by Plaintiff Nike, Inc. to approve consent judgment as to a Certain Defendant

Exhibit A

ATTORNEY Appearance for Defendants MATTAY SKIN LLC., UUSSAAA by Adam Edward Urbanczyk

MOTION by Defendants MATTAY SKIN LLC., UUSSAAA for extension of time

MINUTE entry before the Honorable John J. Tharp, Jr:Nike's motion to approve consent judgment as to defendant no. 87 [60] is granted. Enter Consent Judgment Order. Mailed notice

CONSENT Judgment Signed by the Honorable John J. Tharp, Jr on 1/30/2024. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Defendants MATTAY SKIN LLC., UUSSAAA's motion for extension of time to answer [62] is granted. The deadline for those defendants to respond is extended to 2/19/24. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for default judgment [50] is granted, except as to defendants MATTAY SKIN LLC., UUSSAAA. Enter default judgment order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 1/30/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order[67] in the amount of $175,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 68, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants Nos. 84 and 85. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: No answer having been filed by defendants MATTAY SKIN, LLC and UUSSAAA by the deadline of 2/19/24 set by the Court on 1/30/2024 [65], Plaintiff is directed to file a status report by 8/26/24. Mailed notice

MOTION by Plaintiff Nike, Inc. for entry of default as to Defendant Nos. 15 and 31, MOTION by Plaintiff Nike, Inc. for default judgment as to Defendant Nos. 15 and 31

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[71]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[72]

Exhibit 1

STATUS Report per [70] by Nike, Inc.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for default judgment as to defendant nos. 15 and 31 [71] is granted. Enter default judgment order. Mailed notice

DEFAULT Judgment Orde. Signed by the Honorable John J. Tharp, Jr on 8/27/2024:Mailed notice

FULL SATISFACTION of Judgment regarding order[67] in the amount of $175,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [77], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 47. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The Court having entered default judgment as to the last remaining defendants [75], this case is terminated. Mailed notice

MAILED trademark report with order dated 11/19/2024 to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Nike, Inc.for Release of Bond

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for release of bond [81] is granted. Enter disbursement order. Mailed notice

ORDER To Release Bond to Planitiff Signed by the Honorable John J. Tharp, Jr on 11/27/2024. Mailed notice

MAILED original one hundred nineteen-thousand dollar ($119,000) surety bond posted by Nike, Inc. to Justin R. Gaudio Greer, Burns & Crain Ltd. 200 West Madison St Suite 2100 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7775 91. (Text entry; no document attached.)

RETURN of executed CERTIFIED RECEIPT number 9589 0710 5270 0579 7775 91.

FULL SATISFACTION of Judgment regarding order[67] in the amount of $175,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon the plaintiff's report of full satisfaction of judgment [85], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 44. Mailed notice