2024-cv-00112

COMPLAINT filed by Hallmark Licensing, LLC ; Filing fee $ 405, receipt number AILNDC-21487083.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

EXHIBIT by Plaintiff Hallmark Licensing, LLC Schedule A regarding complaint 1 Modified on 2/9/2024.

MOTION by Plaintiff Hallmark Licensing, LLC for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hallmark Licensing, LLC

Notice of Claims involving Trademarks by Hallmark Licensing, LLC

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable David M. Weisman. 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 Hallmark Licensing, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Hallmark Licensing, LLC 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 Elizabeth Tassi regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

EXHIBIT by Plaintiff Hallmark Licensing, LLC Exhibit 3 - Parts 1-6 regarding declaration 14 Modified on 2/9/2024.

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

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

MEMORANDUM by Hallmark Licensing, LLC 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 leave to file 3, motion for miscellaneous relief 16, motion for temporary restraining order 11 before Honorable Elaine E. Bucklo on 1/11/2024 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 1/25/2024, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 1/18/2024. 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 2/26/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 2/20/2024, 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.

TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 1/11/2024. Mailed notice. Modified on 2/9/2024.

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

MOTION by Plaintiff Hallmark Licensing, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Hallmark Licensing, LLC in support of extension of time 22

(Declaration of Rachel S. Miller)

NOTICE of Motion by Rachel S Miller for presentment of extension of time 22 before Honorable Elaine E. Bucklo on 1/24/2024 at 09:45 AM.

SURETY BOND in the amount of $ 10,000 posted by Hallmark Licensing, LLC. (Document not Imaged)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 22 is granted to 2/8/2024. Mailed notice.

MOTION by Plaintiff Hallmark Licensing, LLC for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Hallmark Licensing, LLC in support of motion for preliminary injunction 27

Declaration of Rachel S. Miller

(Exhibit 1)

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction 27 before Honorable Elaine E. Bucklo on 2/8/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Hallmark Licensing, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/5/2024, answer due 2/26/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for preliminary injunction as to certain defendants 27 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 Elizabeth Tassi 15 and the TRO 21. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Elaine E. Bucklo on 2/8/2024. Mailed notice.

NEW PARTIES: Dongguan Orui Toys & Gifts Co., Ltd., Shenzhen Levin Toys & Gifts Co., Limited, Shenzhen Yingii Industry Co., Ltd., Yangzhou Babyjoy Art& Craft Co., Ltd., Yangzhou Detuo Trading Co., Ltd., Yiwu Juexin Outdoor Goods Co., Ltd., Zhuji Qibow Trading Co., Ltd., Aidmi US, Best Love Quotes, bingqibaihuodian, BNITOAM, Bushanb, CENJIANGG, dalishanghang, Firespit (Fast Delivery 7 - 15 Days), Fotoobackdrops, -fsadaada, Good luck is at hand, Grand Di, guangzhouboqiushangmaoyouxiangongsi, guangzhourujunshangmaoyouxiangongsi, GuzaGift, hefeishiranboyangdianzishangwuyouxiangongsi, Henan Kanluan Trade Co., Ltd, hkdzsw, HONROY, jiameinishop, Keilis, Kekeduck, kun ming jin jian shang mao you xian gong si, KYKU, Le Ngoc 888, leasdia, Lecky Sean James, Limicounts, liuouan, Liyp, Loanhoangcpst, LONGCAOSHEWEN, LXMDengJixiaodian, MasonMouse, Minifitbest, Molongi, ojres, paehe, Qikita, qinrenerxinmaoyi, QueenDale, SHUtingok, SLHLJlin, Somirow, Store Trang Trang, Suhill, THUGIANGPT39, TNOLTK-US, TODOLIA, tongshanxianyaoxuanbaihuodian, tracy Zhong, wangxiao123456tt, WENIANRU, xiangtandianzishangwuyouxianzerengongsi, xiangyangshisongajuanshangmaoyouxiangongsi, xmsrnf, XVBBCNASDF, zengduquyuzhilubaihuoshanghang, ZHANGb, pop2019, dieuminhanh, huicabbages_8, lizhenkai, maxvip, phuhuy-87, quang5915, saw_2593, star81has, HHongHongH, HUANGHUANG, Janue, Sametime, stylish romance, Txinxinfushi, 8XCreative, Alego Co.ltd, Bicheness, CDYHYHeng Co.ltd, Ceiather, GVN Tech, GZZYDZSWYX.Co.ltd, Hamiiimisi, HOKARUA, Product, Romansa, Sharp Cow, SHIREFIL, YORTOOB GY, Best for your heart, For Sweet Dreams, gearden, Left Right Left, paipaibaba and xiejunfei2464 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

STATUS Report pursuant to 20 by Hallmark Licensing, LLC

(Exhibit A)

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with several defendants. Status hearing is reset for 3/26/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 3/19/2024. The court will enter a scheduling order in response to the status report. Mailed notice.

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Jennifer Van Nacht

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendant

SUMMONS Returned Executed by Hallmark Licensing, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2024, answer due 4/8/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

STATUS Report pursuant to 37 by Hallmark Licensing, LLC

(Exhibit A)

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff are engaged in settlement negotiations with several defendants. Plaintiff will move for default judgment against remaining non-dismissed at a later date where appropriate. Status hearing is reset for 4/30/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 4/23/2024. The court will enter an order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to Certain Defendants

MOTION by Plaintiff Hallmark Licensing, LLC for entry of default, MOTION by Plaintiff Hallmark Licensing, LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Hallmark Licensing, LLC in support of motion for entry of default, motion for default judgment 49

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 50

(Exhibit 1)

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment 49 before Honorable Elaine E. Bucklo on 4/19/2024 at 09:45 AM.

(Exhibit A)

STATUS Report per 44 by Hallmark Licensing, LLC

(Exhibit A)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment 49 against all defendants remaining is granted. Enter Default 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 Plaintiff Hallmark Licensing, LLC or its counsel Greer Burns & Crain, Ltd. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 4/25/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order 55 in the amount of $100,000 as to certain defendant

ATTORNEY Appearance for Defendant Kekeduck by Anthony H. Son

MOTION by Defendant Kekeduck to set aside judgment (vacate Default Judgment)

Exhibit Exhibit - A Official Guidance

Declaration Declaration of Liping Chen

(Exhibit Exhibit 1 to Chen Decl.)

ATTORNEY Appearance for Defendant Kekeduck by Anthony H. Son (Revised)

Agreed STATEMENT by Hallmark Licensing, LLC regarding Briefing Schedule of Defendant's Motion to Vacate Default Judgment 58

MINUTE entry before the Honorable Elaine E. Bucklo: The court adopts the agreed statement regarding briefing schedule of Defendant's motion to vacate default judgment 58. Plaintiff's response is due by 2/11/2025. Defendant reply is due by 2/25/2025. Ruling set for 3/21/2025. The court will issue ruling by mail. Mailed notice.

RESPONSE by Plaintiff Hallmark Licensing, LLC in Opposition to Defendant Kekeduck's Motion to Vacate Default Judgment 58

DECLARATION of Jennifer V. Nacht regarding Response 62

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

Exhibit 9

(Exhibit 10)

DECLARATION of Daven Brodess regarding Response 62

(Exhibit 1)

REPLY by Kekeduck to MOTION by Defendant Kekeduck to set aside judgment (vacate Default Judgment) 58, Response 62

Declaration Declaration of Liping Chen

Exhibit Exhibit A to Chen Decl.

Declaration Declaration of Fengquan Li

(Exhibit Exhibit A to Li Declaration)

MOTION by Plaintiff Hallmark Licensing, LLC for leave to file Surreply to Defendant's Reply to Plaintiff's Response in Opposition to Defendant's Motion to Vacate Default Judgment

(Exhibit A)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file, 66 before Honorable Elaine E. Bucklo on 3/7/2025 at 09:45 AM.

RESPONSE by Kekeduckin Opposition to MOTION by Plaintiff Hallmark Licensing, LLC for leave to file Surreply to Defendant's Reply to Plaintiff's Response in Opposition to Defendant's Motion to Vacate Default Judgment 66

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for leave to file surreply to defendant's reply to plaintiff's response in opposition to defendant's motion to vacate default judgment 66 and the response in opposition 68 are taken under advisement. Mailed notice.

ORDER: Plaintiff's motion to file a sur-reply is granted. Defendant Kekeduck's motion under Fed. R. Civ. P. 60(b)(4) to vacate the default judgment entered against it is denied. Signed by the Honorable Elaine E. Bucklo on 3/31/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order 55 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment in the amount of $100,000 as to a Certain Defendant