2024-cv-00143

COMPLAINT filed by PRL USA Holdings, Inc., Ralph Lauren Corporation; Filing fee $ 405, receipt number AILNDC-21491432.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Schedule A regarding complaint 1

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by PRL USA Holdings, Inc., Ralph Lauren Corporation

Notice of Claims Involving Trademarks by PRL USA Holdings, Inc., Ralph Lauren Corporation

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Andrea R. Wood. 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 Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation 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 Alice Pang regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Exhibit 3 - Parts 1-6 regarding declaration[14]

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 11, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 16 are set for a telephonic motion hearing on 1/16/2024 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing and continued to January 30, 2024, at 9:00 a.m. For the reasons stated on the record, Plaintiffs' motion for leave to file under seal [3], Plaintiffs' ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11], and Plaintiffs' motion for electronic service of process [16] are granted. Enter sealed TRO. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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.

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 PRL USA Holdings, Inc. (Document not Imaged)

NOTICE of Voluntary Dismissal by PRL USA Holdings, Inc., Ralph Lauren Corporation as to certain Defendants

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for preliminary injunction 25

Declaration of Marcella D. Slay

(Exhibit 1)

SUMMONS Returned Executed by PRL USA Holdings, Inc., Ralph Lauren Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/25/2024, answer due 2/15/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 1/30/2024. Only Plaintiffs appeared. For the reasons stated on the record, Plaintiffs' motion for entry of a preliminary injunction as to certain defendants [25] is granted. Enter Preliminary Injunction Order. The Temporary Restraining Order expires on its own terms as to the remaining defendants. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2], (2) Exhibit 3 - Parts 1-6 [15], and (3) the sealed temporary restraining order [22]. Plaintiffs' counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 3/19/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 1/30/2024. Mailed notice

NEW PARTIES: Black King2 Store, Kitty Store, Shop1102859429 Store, Shop1102963262 Store, Shop1103181379 Store, Wang Zi Mei Store, Cheerful China shopping Store, Chinaproduce Store, LLDOK Store, Qiansirong2 Store, SDFGDS Store, Shop1102731243 Store, Shop1102899070 Store, Shop1102941375 Store, Shop1103104261 Store, Shop1103140154 Store, Weixier Official Store, BMJT, LederleiterUSA, LiWeiJiecup, Nepena, perfectobagus, Ranessa, starry SKY, xiaojie123, ZhangXinYuezz, abc2688793, ai828, alpsopk, angelao, ao62, archer12, bag099, bai09, basop6, beautifulfashionbag, bei04, beqx, billfold98, bmw740i, boutique_clothing950, brandsfashion, brandsluxurys, bsmne6197xj, bv17, bxeshop1688, cdxjhsmyxgs, clotheswholesale2, cozyroom8, customerfirst1, d72f, dao02, daye01, designer_bags18, designerbag1888, designerbag724, dfrr, dhgatesalevip, dhgatesvip5, dlvapes, dmj1, douboutique1952, edoa, eh7b, eyfa, fallinlovebag, fania_01, fashion611, fashionbags_666, femalebag3333, fionai, fjdmzddm, fjxp13, fjxp7, freely_y, fu2p, fzctu4, fzqfm0906, gdol, gfyj, glcstores, goldmood, guaniu7, hahaa11, hanxi111, hemt, higuess, hkmo, hkzhangli, hobobags, holders68, hoodiellz0047, hu03, huafei01, huangdasdwd, hvzm, hxhk123, hxhkhuang, jewelrys_designer, jewelryshop99, ji05, jiaojiaoma, jin01, jjmp520, leonard5011, leonard5012, lianwu06, liumu7756, liying1233 and liying33 added to case caption. (Text entry; no document attached.)

NEW PARTIES: logo_brands, lookfriend, lookshop, lopiuii, louis_va_store, louiseviutionbag, luxo5586, luxury_eecho, mengni88, merson, mjht, niao03, nicebag111, nqcq, nrd5, ob7p, oiqg, ouyz, pamela56, picril1999, pingbuqingyun888, powerfuo, pparies, psychoo, qualitybags_11, qualitypackage, quan01, quqx, rmsa, shba, smarteara, soundbag, superbags666, supernow, sweaterss, taobushop, tianhua99, titi896, todaynicebuy, tophat8899, trapstar99, trend_shop_2, tshirtllz0047, tu6v, u9ov, ub1h, udfyfnf200, ueze, uvkc, vgvt, vivid695, waist, wmomo2, wr0p, wxb1122, xbo27, xilea, xinyaomaoyi, xinyifashionbag, xswlhh, xuan03, y2kx, yesun_woman88, yiwang10, yj2u, yjfysc, ymc8, yongde66, youngstore03, yumira258, zhanglihuang, zhanglihuangk666, zhi02, zhichao1, zhichao3, zhichao8, zhichao9, zjxnszhu66, zkoh, zodiacs, zshy666, zykz, srdv1674, A creative in cloth, Baby shoes for toddlers, digefashion, DownTown Clothing, Ichingclothes, Kalon, KnownFashionStyle, Printing element, SSSEFLEE, SUITABLES, Tell you my whole life, W club, whatwear, Wild Yi fashion, XL Fashion, Yeonhee women clothing, Yipin Clothing, CM Beauty, Cornelius E Mann, Cozy Ranch, fashionshop20150212 and huangyao5319 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

SUMMONS Returned Executed by Ralph Lauren Corporation, PRL USA Holdings, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/2/2024, answer due 2/23/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for entry of default, MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for entry of default, motion for default judgment, 34

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 35

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for entry of default and default judgment [34] will be heard at the telephonic hearing set for 3/19/2024 at 9:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 3/19/2024. Only Plaintiffs appeared. For the reasons stated on the record, Plaintiffs' motion for entry of default and default judgment [34] is taken under advisement. By 3/26/2024, Plaintiffs shall file a supplemental chart that identifies which Defendants are the subject of the trademark claims and which are the subject of the copyright claims, including an additional column that identifies each Defendants' requested statutory damage amount. Plaintiffs may also make a supplemental filing regarding the propriety of the requested injunctive relief for all Defaulting Defendants regardless of whether they are liable for trademark infringement or copyright infringement. Telephonic status hearing set for 4/9/2024 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

SUPPLEMENT to motion for entry of default, motion for default judgment, 34

Exhibit 1

(Exhibit A)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

ATTORNEY Appearance for Defendant Yipin Clothing by Hua Chen

RESPONSE by Yipin Clothingin Opposition to MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for entry of default MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for default judgment as to all Defendants [34]

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/9/2024 and continued to 4/23/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

REPLY by PRL USA Holdings, Inc., Ralph Lauren Corporation to response in opposition to motion, 44

(Exhibit A)

DECLARATION of Quinn B. Guillermo regarding reply to response to motion 46

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/23/2024 and continued to 5/7/2024 at 9:45 a.m. The Court notes the Defendant's Opposition filed on 4/9/2024 44 as to the Plaintiff's Motion for Entry of Default 34. For all the reasons stated on the record, the Court will not proceed with entry of default or default judgment as to Defendant Yipin Clothing at this time. Defendant Yipin Clothing, only, is granted leave to file an answer to the complaint by 4/30/2024, or in the alternative, notify the Court that a settlement has been reached. Otherwise, the Court will move forward with an entry of default. Plaintiff's counsel shall submit a revised proposed order for the Motion for Entry of Default 34 with a revised list of the remaining Defendants in this case. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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.

***Telephonic status hearing held on 4/23/2024. (Text entry; no document attached.)

ANSWER to Complaint by Yipin Clothing

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/7/2024. As stated on the record, if no settlement is reached by 6/3/2024, the parties shall file a joint written status report, not to exceed five pages in length. The initial status report shall provide the information described on the Court's website at www.ilnd.uscourts.gov under District Judges, Judge Andrea R. Wood, Initial Status Conference. Telephonic status hearing set for 6/5/2024 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

STATUS Report (Joint) Pursuant to [51] by PRL USA Holdings, Inc., Ralph Lauren Corporation

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/5/2024. As discussed on the record, the case is referred to the magistrate judge for the purpose of conducting a settlement conference between Plaintiffs and Defendant Yipin Clothing. The Court adopts the parties' proposed case schedule. The parties shall serve Fed. R. Civ. P. 26(a)(1) initial disclosures by 7/16/2024. Fact discovery shall be completed by 12/16/2024. Dispositive motions shall be filed by 2/18/2025. By 8/5/2024, the parties shall file a joint status report setting forth: (1) the status of discovery, including what progress has been made, whether the parties are aware of any discovery disputes that will require the Court's involvement, and whether the parties are aware of any reason why they will not be able to complete fact discovery by the 12/16/2024 deadline; (2) the status of the parties' settlement discussions with the magistrate judge; and (3) any other issues of concern that the parties would like to bring to the Court's attention. Telephonic status hearing set for 8/13/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation to strike answer to complaint 49

DECLARATION of Quinn B. Guillermo regarding motion to strike 56

Exhibit 1

Exhibit 2

Exhibit 3

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Exhibit 11

Exhibit 12

Exhibit 13

Exhibit 14

(Exhibit 15)

ATTORNEY Appearance for Defendant Yipin Clothing by Daniel I. Konieczny

RESPONSE by Yipin Clothingin Opposition to MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation to strike answer to complaint[49] [56]

REPLY by PRL USA Holdings, Inc., Ralph Lauren Corporation to response in opposition to motion 59

ATTORNEY Appearance for Defendant Yipin Clothing by Lan Li

ATTORNEY Appearance for Defendant Yipin Clothing by Christopher Paul Keleher

MOTION by Attorney Daniel Konieczny and Hua Chen to withdraw as attorney for Yipin Clothing. No party information provided

MINUTE entry before the Honorable Andrea R. Wood: Motion by counsel to withdraw as attorney [63] is granted. Attorneys Daniel I. Konieczny and Hua Chen are terminated as counsel of record. Mailed notice

STATUS Report (Joint) Pursuant to 55 by PRL USA Holdings, Inc., Ralph Lauren Corporation

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/13/2024 and continued to 9/3/2024 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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

STIPULATION of Dismissal (Joint)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 9/3/2024. As discussed on the record, Plaintiffs' motion for entry of default and default judgment [34] is granted. Enter Order. Plaintiff and Defendant Yipin Clothing having filed a stipulation of dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii) [67], the claims against Defendant Yipin Clothing are dismissed without prejudice and with the parties granted leave to reinstate on or before 5/27/2025. If a motion to reinstate is not filed by 5/27/2025, the claims against Defendant Yipin Clothing shall be dismissed with prejudice without further order of the Court. As all claims as to all Defendants have been resolved, this matter is closed. Any pending motions are stricken. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/6/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order 69 as to certain defendants

FULL SATISFACTION of Judgment regarding order 69 as to certain defendant