2024-cv-01908

COMPLAINT filed by The Liverpool Football Club and Athletic Grounds Limited; Filing fee $ 405, receipt number AILNDC-21715260.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Schedule A regarding complaint 1

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Liverpool Football Club and Athletic Grounds Limited

Notice of Claims Involving Trademarks by The Liverpool Football Club and Athletic Grounds Limited

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Maria Valdez. 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.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited 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 Paul Dicken regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Exhibit 3 - Parts 1-9 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

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Exhibit 3-6

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Exhibit 3-8

(Exhibit 3-9)

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for miscellaneous relief 18

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

Exhibit 1

(2)

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum 21

Exhibit 1

Exhibit 2

Exhibit 3

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Exhibit 7

(Exhibit 8)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's Ex Parte Motion for Entry of A Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, and Expedited Discovery 13, and Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) 19. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 3/15/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any Defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain Defendants from the case under Rule 21 at that time. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 3/13/2024. Emailed notice

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

Registry Deposit Information Form by The Liverpool Football Club and Athletic Grounds Limited

BOND in the amount of $10,000.00 check, Receipt No. 100003831, posted by The Liverpool Football Club and Athletic Grounds Limited. Modified on 3/18/2024. (Text entry; no document attached.)

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for preliminary injunction 26

Declaration of Justin T. Joseph

(Exhibit 1)

SUMMONS Returned Executed by The Liverpool Football Club and Athletic Grounds Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/26/2024, answer due 4/16/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's Motion for an Entry of a Preliminary Injunction as to Certain Defendants 26 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2 ; (2) Exhibit 3 to the Declaration of Paul Dicken 17 ; and (3) the TRO 24. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Emailed notice.

(Add and Terminate Party) (axc)

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 3/27/2024. Emailed notice

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Jennifer Van Nacht

NEW PARTIES: Dongguan Ustar Gifts Co., Ltd., Guangzhou Pamei Jewelry Co., Ltd, Guangzhou Ristar Jewelry Co., Ltd., Guangzhou TUHE Jewelry Co., Ltd, Kunshan Xinyuejia Arts & Crafts Co., Ltd., Shaoxing Welmade Stationery & Sports Co., Ltd., Zhongshan City Hongfeng Gift & Craft Co., Ltd., A164NKDGV4EGQY, A1ADPMKQS59VJ2, A1AGT8SNXRH0R4, A1IZP6ZKGPBE8U, A37D1W6LBKLU31, Anna mall, ATWQ9LSOKWAZV, AUHL87LX8C8JX, brodyshop, CHEN1QINGQING, CHEN2YITING, CO-RISING, Dandan Art Decoration Store, Dsforu, Eteral trade, Everyday Elegance Emporium, FuJie Art Store, guangzhoujuhengqichikejiyouxiangongsi, Hang Jun department store, HEYITONG, HEZHENZHU, HFCRYDZSWYXGS, Highly rated shop, hirnegte shop, HW shopping, JIANG1HAINING, Just act coquettish, Jvyaeen, Keeijuiop, Kongming lantern, kunminggaojieshangmaoshanghang, kunmingshubingshangmaoyouxiangongsi, kunmingwankunbaihuoyouxiangongsi, LiveStar, LuoLiMaoYi(GuangZhou)YouXianGongSidhd, makaikaiplus, method deals with, mingshu very well, Occasional Encounter, Open Surround, Pengwang, poweroy, qufeidedian, Quiet and leisurely, Robeen, RYYSTORE, Sedrachkova, Showfine International, Small Bell Cat, Special Southh, sport store shop right, Suifeng Trading, syiboo, Tianli Store, Tuyu department store, WANGCHANGJIANG, WTSLINGYANG, xiangyangshisuwangshangmaoyouxiangongsi, xianyouxianbangtouzhenzhengzhiweitiyuyongpinshangd, xiaoyuBoutique, xitangdianzi, YANGXIYUAA, Yiiiosste, yizhestore, yongjijiechengwangluokejiyouxiangongsi, youmaifuzhuang, yunchengshiyanhuqudongchengjiedaohuiyunwujindian, Zeming's store, ZHOU1HUI, zII sport store, zyhe shoping store, Jersey2024, lingmeiudcn, chinajerseyssuppliers1, huangguan966, BEYOND ART, Hao Kul automotive supplies, KUIOLP, beone-store.com, billinhome.com, gmkits1.com, kkgoold.com, mmjerseys00.com, best96C.Store, chang fashion, fjxxyouth0116, jnugi2shop, pengbo1, wangming6435, Waou, yjueiroi wtaw and yuefgsdkjs58 added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction as to certain Defendants

EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Exhibit A regarding MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction as to certain Defendants 32

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for preliminary injunction 32

Declaration of Justin T. Joseph

(Exhibit 1)

SUMMONS Returned Executed by The Liverpool Football Club and Athletic Grounds Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/10/2024, answer due 5/1/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction as to Defendants 1-7 32 is granted. Enter Preliminary Injunction Order. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Franklin U. Valderrama on 4/11/2024. Mailed notice.

ATTORNEY Appearance for Defendant CO-RISING by Kyle Andrew Migliorini

ATTORNEY Appearance for Defendant CO-RISING by Kyle Andrew Migliorini

ATTORNEY Appearance for Defendant CO-RISING by Kyle Andrew Migliorini

MOTION by Defendant CO-RISING to dismiss for lack of jurisdiction

Declaration

Exhibit

(Exhibit)

SUPPLEMENT to motion to dismiss/lack of jurisdiction 41

MINUTE entry before the Honorable Franklin U. Valderrama: The Court is in receipt of Defendant Co-Rising's Motion to Dismiss for Lack of Personal Jurisdiction and Improper Service and Motion to Reconsider Improper Joinder 41. On or before 05/09/2024, Plaintiff shall file a response. On or before 05/23/2024, Defendant shall file a reply. Mailed notice.

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited to compel and Stay Briefing Schedule (Opposed)

Declaration of Justin Joseph

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

MINUTE entry before the Honorable Franklin U. Valderrama:The Court has reviewed Plaintiff's Opposed Motion to Compel and Stay Briefing Schedule 44. For the reasons stated in the Motion, Defendant CO-RISING is directed to respond in full to Plaintiff's discovery requests as authorized under the Temporary Restraining Order 24 on or before 05/29/2024. The Court stays the briefing schedule 44 until 05/29/2024. Pending the conclusion of the stay, Plaintiff shall file a response to Defendant CO-RISING's motion to dismiss 41 on or before 06/19/2024. Defendant CO-RISING shall file a reply on or before 07/03/2024.

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to a Certain Defendant

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for entry of default, MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for default judgment as to all Defendants with the Exception of a Certain Defendant

(Exhibit A)

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited 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)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment As to All Remaining Defendants, With the Exception of Defendant Co-Rising (Def. No. 19) 47. Statutory damages are awarded in the amount of $200,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order. By 07/01/2024, Plaintiff is directed to file a status report as to the status of the case against the remaining Defendant. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 5/31/2024. Mailed notice.

STIPULATION of Dismissal as to Defendant CO-RISING

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the Stipulation of Dismissal 52. Pursuant to the Stipulation and Federal Rule of Civil Procedure 41(a)(1), all claims in this action are dismissed with prejudice against Defendant CO-RISING (Def. No. 19). Each party will bear their own costs and attorneys' fee. Defendant CO-RISING's Motion to Dismiss for Lack of Personal Jurisdiction and Improper Service and Motion to Reconsider Improper Joinder 41 and Plaintiff's Opposed Motion to Compel and Stay Briefing Schedule 44 are denied as moot. Mailed notice.

MOTION by Defendants Guangzhou Pamei Jewelry Co., Ltd, Guangzhou TUHE Jewelry Co., Ltd to vacate Default Judgment Order

Declaration

Declaration

Exhibit

Exhibit

ATTORNEY Appearance for Defendants Guangzhou Pamei Jewelry Co., Ltd, Guangzhou TUHE Jewelry Co., Ltd by Ge Lei

MINUTE entry before the Honorable Franklin U. Valderrama: The Court is in receipt of the Opposed Motion to Vacate Default Judgment [54]. On or before 07/31/2024, Plaintiff shall file a response of no more than 7 pages. Mailed notice.

RESPONSE by The Liverpool Football Club and Athletic Grounds Limitedin Opposition to MOTION by Defendants Guangzhou Pamei Jewelry Co., Ltd, Guangzhou TUHE Jewelry Co., Ltd to vacate Default Judgment Order [54]

Declaration of Jennifer V. Nacht

Exhibit 1

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Exhibit 5

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[51] in the amount of $200,000 as to certain defendants

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for Release of Bond

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion to return of the bond [60]. In the motion, Plaintiff indicates that no Defendants remain in the case. However, Defendants Guangzhou Pamei Jewelry Co., Ltd. and Guangzhou TUHE Jewelry Co., Ltd. filed a motion to vacate the Default Judgement Order [54], and the Court set a briefing schedule on that motion [56]. That motion remains pending. By 10/01/2024, the Court directs Plaintiff to file a status report as to Defendants Guangzhou Pamei Jewelry Co., Ltd. and Guangzhou TUHE Jewelry Co., Ltd., and to indicate whether the motion remains pending or has been mooted. Mailed notice

STATUS Report per 61 by The Liverpool Football Club and Athletic Grounds Limited

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's status report 62. Plaintiff reports that Defendant No. 2, Guangzhou Pamei Jewelry Co., Ltd. and Defendant No. 4, Guangzhou TUHE Jewelry Co., Ltd., and Plaintiff, have reached a settlement agreement, and filed a satisfaction as to those Defendants, and the pending motion filed by those Defendants is thus mooted, and no Defendants remain. On that basis, the Court terminates the pending motion to vacate default judgment order 54. For the reasons stated in the motion, the Court grants Plaintiff's motion to return of the bond 60. The ten-thousand-dollar ($10,000.00) cash bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the cash bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 200 West Madison Street, Suite 2100, Chicago Illinois 60606. Civil case terminated. Mailed notice.

ORDER TO RELEASE BOND TO PLAINTIFF: Signed by the Honorable Franklin U. Valderrama on 9/30/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendant