2024-cv-02685

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21817225.

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

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

ATTORNEY Appearance for Plaintiff Nike, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Nike, Inc. by Berel Yonathan Lakovitsky

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

AMENDED complaint by Nike, Inc. against yanlei9075 and the Individuals and Entities Operating yanlei9075 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

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

MINUTE entry before the Honorable Edmond E. Chang: Given the public filing of the amended complaint and Amended Schedule A, R. 13, 14, the motion to seal [3] is terminated. The Plaintiff shall promptly serve the complaint or file a motion for alternative service or other relief. On or before 04/15/2024, the Plaintiff shall file a status report. To track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 04/19/2024 at 8:30 a.m. Emailed notice

MOTION by Plaintiff Nike, Inc. for discovery Expedited

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[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Edmond E. Chang: In light of the need to service process and the good cause established for alternative service, the motion 16 for expedited discovery and the motion 17 to authorized alternative service are granted. The tracking status hearing of 04/19/2024 is reset to 05/10/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 05/03/2024. Emailed notice

STATUS Report per 20 by Nike, Inc.

MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 21, the Plaintiff is awaiting the contact information from platform Wish.com. The tracking status hearing of 05/10/2024 is reset to 05/31/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 05/23/2024, and if Wish.com has not responded yet, the report shall state when the Plaintiff provided the discovery order to Wish.com. Emailed notice

SUMMONS Issued as to Defendant yanlei9075 and the Individuals and Entities Operating yanlei9075

SUMMONS Returned Executed by Nike, Inc. as to yanlei9075 and the Individuals and Entities Operating yanlei9075 on 5/10/2024, answer due 5/31/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

STATUS Report per [22] by Nike, Inc.

MINUTE entry before the Honorable Edmond E. Chang: On review of the status report, R. 24, and the return of service, R. 23, the Defendant's response to the amended complaint is due on 05/31/2024. The Plaintiff reports no contact with the Defendant as of yet. The tracking status hearing of 05/31/2024 is reset to 06/21/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 06/07/2024. If the Defendant does not respond to the amended complaint on time, then the Defendant is deemed in default, and the Plaintiff instead shall file a motion for default judgment in a sum certain by 06/12/2024. Emailed 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 26

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 27

Exhibit 1

Exhibit 2

(Exhibit 3)

STATUS Report per 25 by Nike, Inc.

MINUTE entry before the Honorable Edmond E. Chang: On review of the motion for default judgment [26], the Plaintiff shall file a supplement citing to the docket entry and specific pages that supply the relevant screenshots of the online store. If there is no such docket entry, then the Plaintiff shall include the screenshots in the supplement. ***The supplement is due by 12:00 p.m. on 06/14/2024.***Emailed notice

SUPPLEMENT to motion for entry of default, motion for default judgment 26 per 30

(Exhibit 1)

MINUTE entry before the Honorable Edmond E. Chang: The motion for default judgment is under advisement. The tracking status hearing of 06/21/2024 is reset to 06/28/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: In the absence of a timely response to the amended complaint, the Plaintiff's motion for default judgment 26 is granted. Judgment entered in favor of the Plaintiff and against the Defendant in the amount of thirty-five thousand dollars ($35,000). Permanent injunction entered given the finding of willfulness established by the default, which deems the factual allegations as true. A separate AO-450 judgment shall be entered. The tracking status hearing of 06/28/2024 is vacated. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 06/27/2024. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 06/27/2024. Emailed notice