2024-cv-02026

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21729661.

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 Joan B. Gottschall. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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

AMENDED complaint by Nike, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Nike, Inc. Amended Schedule A regarding amended complaint 13

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 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Joe Pallett regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-10 regarding declaration 18

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

(Exhibit 3-10)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 11-12 regarding declaration 18

Exhibit 3-11

(Exhibit 3-12)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's proposed form of temporary restraining order includes language directing non-party providers of services to defendants to freeze defendants' assets. Proposed TRO ¶ 4. Plaintiff has not filed a certificate of service or indicated that it intends to give notice of its motion 15 for a temporary restraining order to the third-party providers named in ¶ 4. Plaintiff has until and including 3/19/2024 to file a certificate of service upon the third-party providers if plaintiff wishes to do so. If plaintiff does not file a certificate of service by the deadline, plaintiff's motion for a temporary restraining order will be denied without prejudice in accordance with Judge Gottschall's standing order on Lanham Act counterfeiting cases, available from Judge Gottschall's page on the court's website at https://www.ilnd.uscourts.gov/. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc.

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a motion 15 for temporary restraining order. Plaintiff's motion is ex parte as to the defendants, but plaintiff has given notice of the motion 22 to the non-party providers of services to the defendants named in the proposed temporary restraining order (collectively "third-party providers"). The third-party providers have until noon on 3/25/24, to object to plaintiff's request that the court find that it has personal jurisdiction over them and that they are in active concert or participation with the defendants named in schedule A to the complaint. See Fed. R. Civ. P. 65(d)(2). The third-party providers may file an objection in writing or request a hearing, to be conducted via teleconferencing, by sending a message to Chambers_Gottschall@ilnd.uscourts.gov, with a copy to all counsel of record, on or before noon on 3/25/24. Plaintiff is ordered to serve the third-party providers with a copy of this order on or before 3/21/24. Plaintiff must file a certificate of service on or before 3/22/24. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding text entry, 23

ATTORNEY Appearance for Objector ContextLogic, Inc. by Christine Elizabeth Skoczylas

OBJECTIONS of Non-Party ContextLogic Inc.

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

MINUTE entry before the Honorable Joan B. Gottschall: Non-party ContextLogic Inc. ("ContextLogic"), filed an objection 26 to plaintiff's motion for a temporary restraining order in which it states, "Although ContextLogic is a non-party, it does not dispute or contest the Court's jurisdiction over it with respect to the enforcement of a temporary restraining order proposed by Plaintiff that may be entered in this case or any obligations that ContextLogic may have thereunder." ECF No. 26 at 2. ContextLogic further states that it "does not understand Plaintiff to be alleging that ContextLogic is acting in active concert or participation with the named defendants," but it "specifically objects" to any such finding by the court. Id. at 2-3. Based on ContextLogic's non-opposition to the requested relief, plaintiff's motion 15 for temporary restraining order is granted. The court makes no finding on whether ContextLogic is acting in active concert or participation with the named defendants. Also granted is plaintiff's motion 3 for leave to file Schedule A to the complaint (2, 14) and Exhibit 3 (19, 20) to the declaration of Joe Pallet under seal. Enter sealed temporary restraining order. A preliminary injunction hearing to be held by teleconference is tentatively set for April 12, 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 and any e-mail addresses provided for defendants by third parties that includes a link to said website. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Joan B. Gottschall on 3/29/2024. Mailed notice

Registry Deposit Information Form by Nike, Inc.

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

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

MEMORANDUM by Nike, Inc. in support of extension of time 32

(Declaration of Marcella D. Slay)

ATTORNEY Appearance for Defendant Asiman by David Silver

MINUTE entry before the Honorable Joan B. Gottschall: On 4/9/2024, an attorney filed an appearance 34 for defendant Asiman and sent a message to Chambers_Gottschall@ilnd.uscourts.gov requesting to be heard at the preliminary injunction hearing tentatively set for 4/12/2024. In accordance with this request, a hearing on plaintiff's motion 32 to extend the temporary restraining order is set for 4/12/2024 at 10:30 a.m. Appearing defendant Asiman is directed to file its Local Rule 3.2 notice of affiliates by 10:30 a.m. on 4/11/2024. The call-in number for the hearing is (888) 684-8852, and the access code is 6692394. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing. Please click on the hyperlink that will be provided to take you to Judge Gottschall's telephone conference login. From there, join conference as "Guest;" enter your name; type the digits in the picture; click on the "Call Me" option; and fill in your phone number (no hyphens) and name. If you do not have access to a computer, dial (888) 684-8852. As stated above, the access code is 6692394.Mailed notice

ATTORNEY Appearance for Defendant Stary Sky by David Silver

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Stary Sky

MOTION by Defendant Asiman for order to Terminate Party (Unopposed)

(Declaration of D. Silver in Support of Unopposed Motion to Terminate Party)

MINUTE entry before the Honorable Joan B. Gottschall: The unopposed motion 38 to terminate the defendant incorrectly named as "Asiman" and substitute "Stary Sky" as the defendant's correct name is granted. The clerk shall terminate defendant "Asiman." Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Defendant "Stary Sky" has indicated that it intends to appear at the hearing set for 4/12/2024 at 10:30 a.m. By noon on 4/11/2024, the parties are instructed to file position papers, consisting of no more than three pages, describing the arguments and issues they expect to raise at the hearing.Mailed notice

POSITION Papers by Defendant Stary Sky for hearing re text entry, 40 Position Papers

RESPONSE by Plaintiff Nike, Inc. to text entry, 40 - Plaintiff's Position Paper

(Declaration of Justin R. Gaudio)

MINUTE entry before the Honorable Joan B. Gottschall: Telephonic hearing held on Nike's motion to extend the TRO. TRO extended for 14 days (to and including April 26, 2024) as to all defendants other than Stary Sky. TRO as to Stary Sky extended until the close of business (5 pm) April 12 or until a court order is issued changing that time. A court order deciding Nike's motion to extend the TRO as to Stary Sky will be issued before 5 pm on this date. Mailed notice

SUPPLEMENT to Plaintiff's Position Paper 42

NOTICE by Nike, Inc. re supplement 44

RESPONSE by Defendant Stary Sky to supplement 44 to Plaintiff's Position Paper

(Exhibit 1 to Defendant's Opposition to Plaintiff's Supplement)

MINUTE entry before the Honorable Joan B. Gottschall: Enter order denying plaintiff's motion 32 to extend the temporary restraining order against defendant Stary Sky. In accordance with the order, plaintiff's brief or motion regarding Stary Sky is due on or before 4/22/2024. Stary Sky's response is due on or before 5/2/2024, and any reply is due on or before 5/7/2024. Mailed notice

ORDER Signed by the Honorable Joan B. Gottschall on 4/12/2024.Mailed notice

MOTION by Plaintiff Nike, Inc. to stay regarding order on motion for extension of time, set motion and R&R deadlines/hearings, set deadlines, 47 (Agreed)

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

SEALED EXHIBIT by Plaintiff Nike, Inc. Amended Schedule A regarding MOTION by Plaintiff Nike, Inc. for Leave to Amend Schedule A to the Complaint Instanter 50

MINUTE entry before the Honorable Joan B. Gottschall: Based on the representation that they have reached a settlement agreement in principle, plaintiff and defendant Stary Sky's joint motion 49 to enlarge by 30 days the briefing schedule set by the order dated 4/12/2024 is granted. Plaintiff's brief or motion regarding Stary Sky is due on or before 5/22/2024. Stary Sky's response is due on or before 6/3/2024, and any reply is due on or before 6/12/2024. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: A preliminary injunction hearing to be held by teleconference is tentatively set for 4/26/2024 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 Pallet, 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

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

(Exhibit A)

MEMORANDUM by Nike, Inc. in support of motion for miscellaneous relief 54

Declaration of Justin R. Gaudio

Exhibit 1

(Exhibit 2)

MOTION by Plaintiff Nike, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction 56

Declaration of Marcella D. Slay

(Exhibit 1)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 50 for leave to amend schedule A to its complaint is granted. In accordance with the amended schedule of defendants 51, the following defendant has been dismissed: Stary Sky, defendant no. 36. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: The court having received no request for a hearing by the deadline 53 of 4/24/2024 at 10:30 a.m., the preliminary injunction hearing set for 4/26/2024 is stricken. Plaintiff's motion for preliminary injunction 56 and motion for electronic service of process 54 are granted. Enter preliminary injunction order. In accordance with the order, the clerk is directed to unseal schedule A to the complaint 2, the amended complaint 14, exhibit 3 to the declaration of Joe Pallett (19, 20), and the temporary restraining order 29. 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 5/24/2024. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Joan B. Gottschall on 4/24/2024.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 Leave to Amend Schedule A to the Complaint Instanter

AMENDED exhibit 2 Amended Schedule A

NEW PARTIES: Chengdu Ibuybi Technology Co., Ltd., Guangzhou Guolian Shoes Development Co., Ltd., Hefei Soonzhuo Import & Export Co., Ltd., Quanzhou Xuanya Trading Co., Ltd., Ruian Jusen Shoes Firm, Shenzhen Zhenfeng Shoes Manufacturing Co., Ltd., Wangdu County Jingmei Shoe Industry Co., Ltd., Wangdu Yuxing Shoes Factory, Wuxing Zhili Qingmi Zhisheng Apparel Factory, Xiamen Yiji Trading Co., Ltd., 50% off - VEKDONE, caokangkashangmaoyouxiangongsi, Chuxue, Destee Yoobee, huikuntandianzishangwuyouxiangongsi, huimoshangmaoyouxiangongsi, HYCSDY, It can be delivered in 8-12 days, JSW-Store, KE Yaoxin 7-15 day delivery, KMRXQ, kunminghurongguojishangmaoyouxiangongsi, kunmingquyiwangluokejiyouxiangongsi, liangtao147, LinYuZhen2003, longliving, Luludianmzishangwu, Made With Love1, majingeshangmaoyouxiangongsi, MOFXWHE, poliushangmaoyouxiangongsi, putianshihanjiangquhuanshaokemaoyiyouxiangongsi, ruoli store, Same_U, SF02727, SUOTO, tangyongdexiaodian, Tasism, Valentine's St Patrick's Day Deals 2024 Aberyty, wangdailinshangmaoyouxiangongsi, Whatsapp+1 7633937243 or Go-copy. com, YourSet Store, abbclothes, adnk88 Store, ajboots_mens_shoes, canadag00semoncler, chuangjian232, fashionzoon01, gantade01, limeidan123, luckysneakers12, luxurystorea, anne_life_1, bagsnbagsonly, bkhj76v8xi0a, stark_97014, zeng52066, ANBAILI Safety Shoes, Yu Feng Socks Industry, 88sneaker.com, g5sneaker.ru, g5sneaker.ru, sunsneakers.com, sunsneakers.com, zngogo.com, CaibaduandKo, ElroyDaisybFeK, fanglimin4761, Geniusisy, GOGOMBB, HanhuigouchengwRe, helang1878, huangju9923, JuliaJodieePsS, Kathleen B Nettles, KebenfeiiA, Kissmelover, liuxiaoming4124, liyingyi9361, MaxwellMarshrJhIgM, OufupanzAb, Phyllis Rose, qiqiuwei010, ruiruiminshop, tanggaohao5306, Tyson J Billiot, wangdong2478, wangjinmei4341, wangruihong6369, wangyueyue04420, Wenxinjiayuanshop, wulei6432, xiaobinbin1234, xuwengjie5414, yangliming0432, zengqinsheng8995, zhaoyi3014, zhoujinxia6825, zhoumaoqun7172 and ZhuoraoweiwB added to case caption. (Text entry; no document attached.)

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/26/2024, answer due 5/17/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 61 for leave to file an amended schedule A of defendants to drop defendant no. 61 is granted. In accordance with the amended schedule of defendants 62, the following defendant has been dismissed: defendant no. 61, Wehilion Market. The preliminary injunction order 60 dated 4/24/2024 is vacated as to defendant no. 61. 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 65 for leave to file an amended schedule A of defendants to drop certain defendants is granted. In accordance with the amended schedule of defendants 66, the following defendants have been dismissed: defendant no. 14, Destee Yoobee; defendant no. 40, Valentine's St Patrick's Day Deals 2024 Aberyty; defendant no. 59, ANBAILI Safety Shoes. The preliminary injunction order 60 dated 4/24/2024 is vacated as to defendant nos. 14, 40, and 59. Mailed notice.

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

AMENDED exhibit 14 Amended Schedule A

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 70

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 71

(Exhibit 1)

STATUS Report per 59 by Nike, Inc.

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 68 for leave to file an amended schedule A of defendants to drop certain defendants is granted. In accordance with the amended schedule of defendants 69, the following defendants have been dismissed: defendant no. 11, 50% off - VEKDONE; defendant no. 33, ruoli store. The preliminary injunction order 60 dated 4/24/2024 is vacated as to defendant nos. 11 and 33.Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Any response to plaintiff's motion 70 for entry of default and for entry of default judgment is due on or before 6/7/2024. The court will rule on the papers unless a hearing is requested on or before 6/7/2024. 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 5/28/2024. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding set motion and R&R deadlines/hearings, 75

(Exhibit A)

ATTORNEY Appearance for Defendants JSW-Store, MOFXWHE by Adam Edward Urbanczyk

ATTORNEY Appearance for Defendant SUOTO by Adam Edward Urbanczyk

MOTION by Defendants JSW-Store, MOFXWHE, SUOTO for extension of time

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by JSW-Store, MOFXWHE, SUOTO

MINUTE entry before the Honorable Joan B. Gottschall: Appearing defendants' motion 79 for an extension to and including 6/14/2024 of their deadline to answer or otherwise respond to the live complaint is granted. 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 82 for leave to file an amended schedule of defendants is granted. In accordance with the amended schedule of defendants 83, defendant no. 34, Same U, has been dismissed.Mailed notice

MOTION by Defendants JSW-Store, MOFXWHE for extension of time

MINUTE entry before the Honorable Joan B. Gottschall: Appearing defendants' motion for an extension of time is granted to and including June 26, 2024. By that date, plaintiff must inform the court whether it objects to appearing defendants' motion to extend their time to and including July 5, 2024. 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 for Leave to Amend Schedule A to the Complaint 87 is granted. Mailed notice

RESPONSE by Plaintiff Nike, Inc. to order on motion for extension of time, text entry, 86

MINUTE entry before the Honorable Joan B. Gottschall: Based on plaintiff's representation 90 that settlement negotiations are no longer occurring, appearing defendants' motion 85 for an extension of their deadline to answer or otherwise respond to the operative complaint is granted to and including July 2, 2024. The court cannot consider plaintiff's request 90 for entry of a separate judgment against defaulting defendants because it is made in a response brief, and appearing defendants have not had an opportunity to be heard. See Fed. R. Civ. P. 7(b). If appearing defendants answer or otherwise respond to the complaint by the deadline of July 2, 2024, plaintiff may, if it wishes, file a motion under Fed. R. Civ. P. 54(b) for entry of a partial judgment against defaulting defendants. Mailed notice

MOTION by Defendants JSW-Store, MOFXWHE for extension of time

MINUTE entry before the Honorable Joan B. Gottschall: Based on defendant JSW-Store's representation 92 that it has settled with plaintiff, its motion 92 for an extension to and including 7/23/2024 of its deadline to answer or otherwise respond to the operative complaint is granted. Defendant MOFXWHE represents 92 that settlement discussions with plaintiff remain ongoing. Defendant MOFXWHE's deadline to answer or otherwise respond to the operative is complaint is extended to and including 7/9/2024. If plaintiff objects to extending defendant MOFXWHE's answer deadline beyond that date, plaintiff must file its objections on or before 7/9/2024. 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 94 for leave to file an amended schedule of defendants dropping defendants JSW-Store and MOFXWHE is granted. Plaintiff having settled with all appearing defendants, plaintiff's motion 70 is granted. Plaintiff's counsel is instructed to send a revised proposed form of default judgment with the current schedule of defendants to Proposed_Order_Gottschall@ilnd.uscourts.gov. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Joan B. Gottschall on 7/16/2024. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall:Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order 97 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 97 in the amount of $500,000 as to certain defendant