2024-cv-02077

COMPLAINT filed by Lululemon Athletica Canada Inc.; Filing fee $ 405, receipt number AILNDC-21736682.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Lululemon Athletica Canada Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lululemon Athletica Canada Inc.

Notice of Claims Involving Trademarks by Lululemon Athletica Canada Inc.

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Thomas Joseph Juettner

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.

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2).

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Lululemon Athletica Canada Inc. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Lululemon Athletica Canada Inc. 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 Jenny Vo regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 1-10 regarding declaration 16

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

Exhibit 4-6

Exhibit 4-7

Exhibit 4-8

Exhibit 4-9

(Exhibit 4-10)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 11-20 regarding declaration 16

Exhibit 4-11

Exhibit 4-12

Exhibit 4-13

Exhibit 4-14

Exhibit 4-15

Exhibit 4-16

Exhibit 4-17

Exhibit 4-18

Exhibit 4-19

(Exhibit 4-20)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 - Parts 21-27 regarding declaration 16

Exhibit 4-21

Exhibit 4-22

Exhibit 4-23

Exhibit 4-24

Exhibit 4-25

Exhibit 4-26

(Exhibit 4-27)

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

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [20] are set for a telephonic motion hearing on 3/28/2024 at 9:15 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 motion hearing held on 3/28/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the domain names, a temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [20] are granted. Enter Sealed Temporary Restraining Order. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2], (2) Exhibit 4 - Parts 1-10 [17], (3) Exhibit 4 - Parts 11-20 [18], and (4) Exhibit 4 - Parts 21-27 [19]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:15 a.m. on 3/28/2024 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 4/11/2024 at 12:30 PM. 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 3/28/2024. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

Registry Deposit Information Form by Lululemon Athletica Canada Inc.

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

MOTION by Plaintiff Lululemon Athletica Canada Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Lululemon Athletica Canada Inc. in support of extension of time[28]

Declaration of Kahlia R. Halpern

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 28 is granted. The Court finds good cause to extend the temporary restraining order an additional 14 days to 4/25/2024. Telephonic status hearing set for 4/11/2024 is stricken and reset for 4/25/2024 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 Plaintiff Lululemon Athletica Canada Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for preliminary injunction[31]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Lululemon Athletica Canada Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/22/2024, answer due 5/13/2024.

Declaration of Thomas J. Juettner

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 4/25/2024. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 31 is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint 2, (2) Exhibit 4 - Parts 1-10 17, (3) Exhibit 4 - Parts 11-20 18, (4) Exhibit 4 - Parts 21-27 19, and (5) the sealed temporary restraining order 25. Plaintiff's 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 6/11/2024 at 9:15 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 4/25/2024. Mailed notice

NEW PARTIES: Yiwu Wangliang Bags Co., Ltd., ZHU JING KANG, abnicesports666, aglobalsports, aliclothes, beaster_01, championnicejerseys, clothing101, clothing102, clothing1713, clothing189, clothing268, clothing907, company68, dandhgate, dhhql, fantastic128, fend_fashion_clothes, igetstore, ivsoccerjerseys, joy7777, keychain68, leeo_hee, lulugymsuit, majorsuit968, mayingclothes88, naviga, newclothes112, newjacket, palms_vinson, penglv688 Store, sheng_clothing, smart_boxes, stuneclothing01, supvinson_01, taoqifang, topstore1103, wxqing02, xian998889, zaqhuadi002, zhiniao Store, zmgse, zzz528013, 23ajkl-8optl.ouo, 58d4rh1d-2, abrsik5b, bagshop888, battery.top.pl66, beachcom888, beautiful-yoga.jl26.o0, beiliushisuiwendianzishangmaoyouxiangongsi, buzhi1_48, charlottswpp9568, chnegzai12, claudig8055, cy94252, endongxi, fubadianzi, gkcontaine-0, grsimpp9989, hai_5224, hndf4chfjm6, hongyan49, houdewenhua, inghangjian, jesbpp8258, jgznli-xq, kashhhine01, kuayue2085, laosbpp59, liurui76845, liuruit-47, lvyuanlou, megawaopti-0, mingwoo0, mirnappo9978, okz-77, parahyyy989, perfect50684, pianxin70, quanxi38, royalra-67, samithp462, shuaiwen8, shuangshu63, specialk208889, stgfjj5286, surpassce, sve507, tacer77867, taosheng381, tarspeigyyt556, vonluxeshop, wencunt_87, xiangyoy, xiuhtradin0, yoga.style-a19.0, yoga_club08.o.o, yunqinkeji, zhiqiong, zhuhui84, zxd_37, lululeca.com, lulugymsale.com, luluoutlets.com, lulusportus.com, lulusaleus.com, lululemonofficialca.com, luluoutletus.com, lululemenwinter.com, lulumonca.com, lulusaleusa.com, lulugym.com, luluoutlet.shop, lulubagus.com, us-lululemon.shop, hilbedo.com, lemathletic.com, spreadds.live, ckdrank.com, lululemonofficial.net, yogavipsale.com, mexicotiendasonline.com, alfdbrew.com, lemonmdu.com, lulu-lemonnederland.com, lulu-lemonmalaysia.com and lulu-lemonphilippines.com added to case caption.

MOTION by Plaintiff Lululemon Athletica Canada Inc. for entry of default, MOTION by Plaintiff Lululemon Athletica Canada Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for entry of default, motion for default judgment 36

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 37

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against the Defendants identified on Schedule A 36 will be heard at the telephonic hearing set for 6/11/2024 at 9:15 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 6/11/2024. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against the Defendants identified on Schedule A [36] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/24/2024. Mailed notice

NOTICE of Removal of Material from the Custody of the Clerk's Office [27]. (Received at the Intake Counter on 07/25/24.)