2024-cv-02792

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21830381.

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.

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

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

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 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Joe Pallett regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-8 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

(Exhibit 3-8)

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 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 16, motion for temporary restraining order 11 before Honorable Charles P. Kocoras on 4/16/2024 at 09:50 AM.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Joan B. Gottschall for all further proceedings pursuant to 28:294(b). Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: In light of the reassignment to Judge Gottschall [20] the motion hearing before Judge Kocoras is stricken. Mailed notice.

MINUTE entry before the Honorable Joan B. Gottschall: Enter order. In accordance with the order, plaintiff has until and including 4/26/2024 to show cause why joinder is permissible in this case. See the order for details. Mailed notice

ORDER Signed by the Honorable Joan B. Gottschall on 4/19/2024. Mailed notice

MEMORANDUM by Nike, Inc. Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum 24

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

(Exhibit 8)

MOTION by Plaintiff Nike, Inc. to withdraw motion for temporary restraining order 11, motion for miscellaneous relief 16

AMENDED complaint by Nike, Inc. against fashionclothesstore and The Individuals And Entities Operating fashionclothesstore 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, 27

MOTION by Plaintiff Nike, Inc. for discovery Expedited

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 26 for leave to withdraw its pending motion 11 for a temporary restraining order and motion 16 for leave to serve process by electronic means is granted. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: On May 6, 2024, plaintiff exercised its right to amend its complaint 27 to drop all but one defendant 28. See Fed. R. Civ. P. 15. The improper joinder issue briefed by plaintiff 23 is therefore moot. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 29 under Fed. R. Civ. P. 26(d) to conduct expedited discovery is granted. Although plaintiff has not filed the affidavit required by Local Rule 5.5(d), plaintiff has filed a declaration in support of its motion for a temporary restraining order 13 providing the information required by that rule. Mailed notice

ORDER Signed by the Honorable Joan B. Gottschall on 5/6/2024. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: A status report on discovery is due on or before 5/20/2024. Mailed notice

STATUS Report per [34] by Nike, Inc.

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[36]

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

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff reports 35 that it intends to file a motion for leave to serve the summons and complaint by electronic means. If such a motion has not been filed by 6/25/2024, a status report is due on that date. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Enter order granting plaintiff's motion [36] for leave to serve the summons and complaint by electronic means. The next status report is due by and including 6/27/2024. Mailed notice.

ORDER Signed by the Honorable Joan B. Gottschall on 5/29/2024. Mailed notice

SUMMONS Issued as to Defendant fashionclothesstore and The Individuals And Entities Operating fashionclothesstore

SUMMONS Returned Executed by Nike, Inc. as to fashionclothesstore and The Individuals And Entities Operating fashionclothesstore on 6/3/2024, answer due 6/24/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's Motion to Seal 3 is granted. Mailed 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[44]

Exhibit 1

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

Exhibit 1

Exhibit 2

Exhibit 3

STATUS Report per [40] by Nike, Inc.

MINUTE entry before the Honorable Joan B. Gottschall: Any response to plaintiff's motion 4 for entry of default and for entry of default judgment is due on or before July 12, 2024. The court will rule on the papers unless a hearing is requested on or before July 12, 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 July 2, 2024. Mailed notice (gel,)

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding text entry, 48

(Exhibit A)

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 48 to request a hearing on, or file a response to, plaintiff's motion for default judgment has come and gone, and nothing has been received. Upon consideration of the certificate of service 49 filed 6/28/2024, plaintiff's motion 44 for entry of an order of default and default judgment is granted. Plaintiff is instructed to send a proposed default judgment, in Word and PDF formats, to Proposed_Order_Gottschall@ilnd.uscourts.gov on or before 8/2/2024. Mailed notice

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

FINAL JUDGMENT ORDER Signed by the Honorable Joan B. Gottschall on 8/5/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order[52] in the amount of $500,000 as to certain defendant