2024-cv-02081

COMPLAINT filed by Pit Viper, LLC; Filing fee $ 405, receipt number AILNDC-21737321.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Pit Viper, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Pit Viper, LLC

Notice of Claims Involving Trademarks by Pit Viper, LLC

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Rachel S Miller

ATTORNEY Appearance for Plaintiff Pit Viper, LLC by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Joan H. Lefkow. 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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Franklin U. Valderrama for all further proceedings. Honorable Joan H. Lefkow no longer assigned to the case pursuant to the provisions of 28 USC 294(b). Signed by Executive Committee on 03/15/2024.

MOTION by Plaintiff Pit Viper, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Pit Viper, LLC in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Vance Lommen regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Pit Viper, LLC Exhibit 2 - Parts 1-7 regarding declaration[17]

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

MEMORANDUM by Pit Viper, LLC in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

MEMORANDUM by Pit Viper, LLC Establishing that Joinder is Proper

Declaration of Justin R. Gaudio

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Plaintiff's motion for a temporary restraining order [14], motion for leave to file under seal [3], and motion for electronic service of process [19]. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on March 22, 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 the 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 that 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 3/20/2024. Emailed notice

Registry Deposit Information Form by Pit Viper, LLC

CHECK BOND in the amount of $ 10,0000.00 posted by Pit Viper, LLC (jcc,) (Text entry; no document attached.)

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

ATTORNEY Appearance for Defendant SENXUAN Co., Ltd by He Cheng

MOTION by Plaintiff Pit Viper, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Pit Viper, LLC in support of extension of time[27]

Declaration of Rachel S. Miller

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order 27. The Temporary Restraining Order 14 shall now expire on 4/19/24 at 6:00 p.m. Enter Order Emailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 4/4/2024. Emailed notice

MOTION by Plaintiff Pit Viper, LLC for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Pit Viper, LLC in support of motion for preliminary injunction[31]

Declaration of Rachel S. Miller

Exhibit 1

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/16/2024, answer due 5/7/2024.

Declaration of Rachel S. Miller

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 [31] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 2 to the Declaration of Vance Lommen [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. Mailed notice.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Franklin U. Valderrama on 4/17/2024. Mailed notice.

NEW PARTIES: Fuzhou Ju Cheng Ren De Trade Co., Ltd., Guangzhou Keheng Industrial Co., Ltd., Hangzhou Modern Eyewear Co., Ltd., Hefei Harong Network Technology Co., Ltd., Jian 'ou Baosonxun Trading Co., Ltd., Linhai Aixi Glasses Factory, Linhai Weihe Glasses Co., Ltd., Linhai Yuchen Eyewear Co., Ltd., Ningbo Gongshan Import & Export Co., Ltd., Ningbo Jiaqi Import And Export Trading Co., Ltd., Qingyuan Speed Sport Products Co., Ltd., Shanghai Mass Eyewear Co., Ltd., Shenzhen Jiu Jiu Yi Trade Co., Ltd., Taizhou Guangxiao Glasses Co., Ltd., Taizhou Hongwei Glasses Co., Ltd., Taizhou Huanyang Glasses Co., Ltd., Taizhou Yimao Glasses Co., Ltd., Wenling Bestone Commodity Factory, Wenzhou Cango Trading Co., Ltd., Wenzhou Chengye Optical Co., Ltd., Wenzhou Croesus Optical Co., Ltd., Wenzhou Faith Import & Export Co., Ltd., Wenzhou Feixun Trading Co., Ltd., Wenzhou Higo Optical Co., Ltd., Wenzhou Honkan Optical Co., Ltd., Wenzhou Kangcheng Eyewear Co., Ltd., Wenzhou Youge Eyewear Co., Ltd., Wenzhou Zhantai Glasses Co., Ltd., Xiamen San Dian San San International Trade Co., Ltd., Yiwu Hong Ya Import & Export Co., Ltd., Yiwu Qiqing Trade Co., Ltd., Yiwu Xiakou Trading Co., Ltd., Yiwu Yudi E-Commerce Co., Ltd., Yiwu Zerui Trading Co., Ltd., Zhengou International Trading (shenzhen) Co., Ltd., balixiangshangmao, BOLLFO, FuYanM, HT HERBS, jingrongshangmaodian, JINGRUITOYS, jiuzixingshangmao ltd, LERTU, linzebinusa001, luckhahaha, MiYiYaMaoYi, POETINT007, RICHFUN, ruimaishangmao ltd, shuting trade, tzx3455, XiYin, xu wen yan, yulinwangluokejigongzuoshi, zhihongjj, ava2024, bdesportjt, burbery_gh, chanel003, chencai2, chencai6, chencaichong, chooseu8, darkclouds8, davidjewelry1, dh_0002, dh_brandstore, dh_gao1, dhgatejewelry_x, dhgater8, dongwei5, fashionstorexst07, femmesss, friday_shop, gh_good_shop3, gh_store1, goodboy_shop1, hat0118, high_quality_gh, highgrade6, hwh002, infinity001, lee_king_glasses, luckyshop01, luxurybrand2glasses, mhick, palmvlone, perfect113, scarf_top, shenmao_sm, spider01, sunglass_wow, sunglasses_belt2, superstar_shop1, thenorthst, tidesunglasses, tmzy8888, topdesigners, vyrfede123, waterstore, woodenarts88, wowgoods, wyfrxs99, xiaohua188, xingwanglong2, zhengcj33, fashion-202306, gzz_122, hxg201288, LeiJun2021, Chenlai Store, LingRan-home decoration and SENXUAN Co.Ltd added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendant

MOTION by Plaintiff Pit Viper, LLC for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Pit Viper, LLC in support of motion for preliminary injunction 37

Declaration Of Rachel S. Miller

(Exhibit 1)

SUMMONS Returned Executed by Pit Viper, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/19/2024, answer due 5/10/2024.

Declaration Of Rachel S. Miller

(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 [37] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 2 to the Declaration of Vance Lommen [18]; 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. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Franklin U. Valderrama on 4/22/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to certain defendant

NOTICE of Voluntary Dismissal by Pit Viper, LLC as to a certain Defendant

MOTION by Plaintiff Pit Viper, LLC for entry of default, MOTION by Plaintiff Pit Viper, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Pit Viper, LLC in support of motion for entry of default, motion for default judgment[44]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against the Defendants Identified in Schedule A 44 is granted. Enter Final Judgment Order. The ten thousand dollar ($10,000.00) cash bond posted by Greer Burns & Crain Ltd., 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., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Franklin U. Valderrama on 5/17/2024. Mailed notice.

MAILED trademark report with copy of order dated 5/17/2024 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 48 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 48 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $200,000 as to certain defendant

MOTION by Plaintiff Pit Viper, LLC to amend/correct order[48]

AMENDED FINAL JUDGMENT ORDER: The Court has reviewed Plaintiff's motion to amend the Court's default judgment order [60], in which it states that the Fiscal Department for the United States District Court for the Northern District of Illinois has informed Plaintiff's counsel that an amended order will be needed to correct the prior default judgment order [45], to remove the "certified mail language" because the Fiscal Department only sends checks via regular mail, not certified mail. Accordingly, the Court enters the amended final judgment order. Signed by the Honorable Franklin U. Valderrama on 9/15/2025. Mailed notice.