2024-cv-01660

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21685540.

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 Charles P. Kocoras. 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.

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 1-6 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[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 temporary restraining order[11], motion for leave to file[3], motion for miscellaneous relief[16] before Honorable Charles P. Kocoras on 3/5/2024 at 10:30 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for temporary restraining order 11, motion to file under seal 3, and motion for electronic service 16 are granted. The hearing on 3/5/2024 at 10:30 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 3/1/2024.Mailed notice.

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Joan B. Gottschall for all further proceedings pursuant to the provisions of 28 USC 294(b). Honorable Charles P. Kocoras no longer assigned to the case. Signed by Executive Committee on 3/5/24.

SURETY BOND in the amount of $ 10,000 posted by Nike, Inc. (Document not scanned.)

MINUTE entry before the Honorable Joan B. Gottschall: The sealed temporary restraining order [21] expires on 3/15/2024. Accordingly, a preliminary injunction hearing, to be held by teleconferencing, is tentatively set for 3/14/2024 at 10:30 a.m. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 3 to the declaration of Joe Pallett, as well as to any e-mail addresses provided for defendants by third parties. Any notice must include a link to said website.Mailed notice

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

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

MEMORANDUM by Nike, Inc. in support of extension of time[25]

Declaration of Marcella D. Slay

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 23 to request a hearing has come and gone, and no request for a hearing has been received. Accordingly, plaintiff's motion 25 to extend the sealed temporary restraining order 21 to and including 3/29/2024 is granted. Enter order. The preliminary injunction hearing tentatively set for 3/14/2024 at 10:30 a.m. is stricken and reset to 3/29/2024 at 10:30 a.m. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants by electronically publishing a link to the complaint, the temporary restraining order, and other relevant documents on a website and by sending an e-mail to the e-mail addresses identified in Exhibit 3 to the declaration of Joe Pallett 15, as well as to any e-mail addresses provided for defendants by third parties. Any notice must include a link to said website. Mailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER Signed by the Honorable Joan B. Gottschall on 3/14/2024. Mailed notice

MOTION by Plaintiff Nike, Inc. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[29]

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 3/26/2024, answer due 4/16/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Joan B. Gottschall: The court having received no request for a hearing by the deadline 27 of 3/27/2024 at 10:30 a.m., the preliminary injunction hearing set for 3/29/2024 at 10:30 a.m. is stricken. Plaintiff's motion for preliminary injunction 29 as to defendant nos. 9-97 is granted. Enter preliminary injunction order as to defendant nos. 9-97. In accordance with the order, the clerk is directed to unseal Schedule A to the complaint 2, Exhibit 3 to the Declaration of Joe Pallett 15, and the temporary restraining order 21. The law firm of Greer, Burns & Crain Ltd. is hereby ordered to add ALL defendant names listed in 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. The next status report is due on or before 4/26/2024. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Joan B. Gottschall on 3/27/2024. Mailed notice

NEW PARTIES: Fuzhou Nikesi Electronic Commerce Co., Ltd., Guangzhou Lionsroaring Trading Limited Company, Guangzhou Naxier Trading Co., Ltd., Hangzhou Karong Yunshang Technology Co., Ltd., Jinjiang Moroso E-Commerce Co., Ltd., Quanzhou Get Right Technology Co., Ltd., Quanzhou Lingfei Shoes & Clothing Co., Ltd., Quanzhou Shunfayu Trading Co., Ltd., binzhouqufuziyibaihuodian, kunmingjiexuanguojimaoyiyouxiangongsi, putianshihanjiangqucheguangyumaoyiyouxiangongsi, Reed-CA, shensa, WANGCUNXIANGBAO, zhangxiem, a31415931, nuekesports, og_kicks, parra, patagoniag, pk_sneakers, polo886, qinmin123, rhude, running__shoe, runningshoe023, shoesking88, shoestop01, smile_bag1, sneakers500, sneakersshop8, sp5der, sunrisecn Store, superior_stores, superstore9, superuys, taopinhui2, the_joy_of_shoes, tiantian06, top_fortoryshoes, top_quality_shoeshop, top1dunkshoes8888, topsneakers777, trendfashion20, trendsportsshoes, trendyclothing01 Store, tshirtstradestore, ua_sneakers, vega9 Store, versacess Store, vilebrequin, viprunningshoes, wangpengying1 Store, wdgcsmyxgs Store, wenjin003 Store, wenkeyu520, wet_shoes_12, wubicai3333, xabtxclothing Store, xiaolifeidao11, xile688 Store, yanping1, zeroling9 Store, zhang2268, 1688xingx.1, fanlei2696, good pici, heguoe, jrcfjzgc, li1ofzhi, liaokang18546, LR House, Minz Shopping, ncehba, Sunner greetings, zhongren9, zookka, QCMGMG, SENDKEEL, bestwondercloset.com, cheapjeansstore.com, fanwish.cn, gobuyluxury.ru, popshoe.org, topweardealsstore.com, caofei2134, cuihaoyu2844, dongledong3503, liyanfang2476, lvgejunf7276, mengxiaofei0270, shichao6114, songningning2134, wangruran4107, wangxuan2468, XiegudaoeQg and yangchao4811 added to case caption.

MOTION by Plaintiff Nike, Inc.for Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 34 for leave to file an amended schedule A of defendants to drop defendant nos. 12 and 78 is granted. In accordance with the amended schedule of defendants 35, the following defendants have been dismissed: defendant no. 12, Reed-CA; defendant no. 78, QCMGMG. The preliminary injunction order 33 dated 3/27/2024 is vacated as to defendant nos. 12 and 78. Mailed notice

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/8/2024, answer due 4/29/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

MOTION by Plaintiff Nike, Inc.for Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion [38] for leave to amend schedule A to its complaint is granted. In accordance with the amended schedule of defendants [39], the following defendant has been dismissed: SENDKEEL, defendant no. 79. The preliminary injunction order [33] dated 3/27/2024 is vacated as to defendant no. 79. Mailed notice

MOTION by Plaintiff Nike, Inc.for Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion [41] for leave to amend schedule A to its complaint is granted. In accordance with the amended schedule of defendants [42], the following defendant has been dismissed: 1688xingx.1, defendant no. 65.Mailed notice

STATUS Report per 32 by Nike, Inc.

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff reports [44] that it is in active settlement discussions with several defendants. The next status report is due by and including 5/31/2024. Mailed notice

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[46]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[47]

Exhibit 1

MINUTE entry before the Honorable Joan B. Gottschall: Any response to plaintiff's motion 46 for entry of default and for entry of default judgment is due on or before 5/16/2024. The court will rule on the papers unless a hearing is requested on or before 5/16/2024. A hearing, to be conducted via teleconferencing, may be requested by sending a message to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and attorneys who have appeared. Plaintiff is ordered to serve defendants and any affected third-party providers with a copy of this order and file a certificate of service on or before 5/6/2024. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding set motion and R&R deadlines/hearings, [49]

Exhibit A

Exhibit B

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 49 of 5/16/2024 to object to plaintiff's motion 46 for entry of default and default judgment has come and gone, and no objection has been filed. Plaintiff's motion 46 for entry of default and default judgment is granted. Enter default judgment. Civil case terminated.Mailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Joan B. Gottschall on 5/22/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendant