2024-cv-02809

COMPLAINT filed by XYZ Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-21832411.

Exhibit 1 to the Complaint

Declaration of S. Mangano in Support of Motion for Leave to File Under Seal

Declaration of S. Mangano in Support of Motion for Leave to File Under Seal [Redacted]

Declaration of S. Mangano in Support of Motion

Exhibit 1 to the Complaint

Declaration of Shawn A Mangano ISO Supplemental Brief ISO Motion to Seal Docket 5

Exhibit Registry Deposit Information Form

Exhibit Memorandum In Support of Motion to Extend TRO

Exhibit Memorandum ISO Motion for Entry of Preliminary Injunction

Memorandum in Support of Motion for Summary Judgment

Exhibit 1 to Supplement

Exhibit 1

Declaration of Zhichao Jiang

Exhibit Memorandum in Support of Motion for Default and Default Judgment

CIVIL Cover Sheet

(Exhibit 2 to the Complaint)

(Exhibit A to the Declaration of S. Mangano)

(A to the Declaration of S. Mangano [Redacted])

Exhibit 1 to the Declaration of S. Mangano

Exhibit 2 to the Complaint

(Exhibit A to the Declaration of SAM ISO Supplemental Brief ISO Motion to Seal)

(Text of Proposed Order)

(Declaration of Shawn A, Mangano In Support of Motion to Extend TRO)

Declaration of Shawn A. Mangano ISO Motion for Preliminary Injunction

Statement of Undisputed Facts

Exhibit 2 to Supplement

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

ATTORNEY Appearance for Plaintiff XYZ Corporation by Shawn Anthony Mangano

Exhibit 2 to the Declaration of S. Mangano

Exhibit Motion for TRO

(Declaration of Liangjie Li ISO Motion for Preliminary Injunction)

Declaration of S. Mangano in Support of Motion for Summary Judgment

Exhibit 3 to Supplement

Exhibit 1 to the Declaration of K. Kuhn

SEALED MOTION by Plaintiff XYZ Corporation

Exhibit 3 to the Declaration of S. Mangano

Declaration of S. Mangano in Support of Motion for TRO

Exhibit A to the Declaration of S. Mangano in Support of Motion for Summary Judg

Exhibit 4 to Supplement

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

MOTION by Plaintiff XYZ Corporation to seal [Redacted]

Exhibit 4 to the Declaration of S. Mangano

Exhibit 7 to the Declaration of of S. Mangano in Support of Motion for TRO

Exhibit B to the Declaration of S. Mangano in Support of Motion for Summary Judg

Exhibit 5 to Supplement

MOTION by Plaintiff XYZ Corporation for leave to file excess pages in Plaintiff's Memorandum in Support of Plaintiff's Motion for Entry of a Temporary Restraining Order

Exhibit 5 to the Declaration of S. Mangano

(Exhibit Notification of Affiliates)

Exhibit 6 to Supplement

MOTION by Plaintiff XYZ Corporation for temporary restraining order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION [Redacted]

Exhibit 6 to the Declaration of S. Mangano

Exhibit 7 to Supplement

SEALED EXHIBIT by Plaintiff XYZ Corporation Complaint for Copyright Infringement

(Exhibit 7 to the Declaration of S. Mangano)

Declaration of Katherine M. Kuhn in Support of Supplement

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff XYZ Corporation by Gokalp Bayramoglu

ATTORNEY Appearance for Plaintiff XYZ Corporation by David Silver

ATTORNEY Appearance for Plaintiff XYZ Corporation by Yasasvin Nandish Wijetilleke (Wijetilleke, Yasasvin Nandish)

CASE ASSIGNED to the Honorable Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 3). (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.)

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto (Text entry; no document attached.)

MOTION by Attorney David Silver to withdraw as attorney for XYZ Corporation. No party information provided

MINUTE entry before the Honorable Jeremy C. Daniel: Motion for leave to withdraw 13 is granted.

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joseph Wendell Droter

STATEMENT by Plaintiff XYZ Corporationin Support of MOTION by Plaintiff XYZ Corporation to seal [Redacted] 5

MOTION by Attorney Yasavin Nandish Wijetilleke to withdraw as attorney for XYZ Corporation. No party information provided (Wijetilleke, Yasasvin Nandish)

MINUTE entry before the Honorable Jeremy C. Daniel: Motion to withdraw as attorney 17 is granted. Mailed notice

MINUTE entry before the Honorable Jeremy C. Daniel: Status report due on or before 7/15/2024. Mailed notice

NOTICE of Motion by Shawn Anthony Mangano for presentment of Sealed motion 4, motion for temporary restraining order, 7, motion for leave to file excess pages 6, motion to seal 5 before Honorable Jeremy C. Daniel on 7/17/2024 at 09:30 AM.

STATUS Report by XYZ Corporation

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. The plaintiff's motions for leave to file under seal 4 and 5, motion to exceed page limitation 6 and ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 13 are granted. Plaintiff shall review prior declaration and, if necessary, file an amended declaration and proposed order reflecting current infringement warranting a temporary restraining order. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 7/17/2024. Mailed notice

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to deposit funds into Court's Registry

MINUTE entry before the Honorable Jeremy C. Daniel: The Plaintiff's motion for leave to deposit funds into Court registry 24 is granted. Mailed notice

SURETY BOND in the amount of $ $5,000.00 posted by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD, XYZ Corporation

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD for extension of time for Temporary Restraining Order

NOTICE of Motion by Shawn Anthony Mangano for presentment of extension of time, 26 before Honorable Jeremy C. Daniel on 7/31/2024 at 09:30 AM.

EXTENDED SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 7/31/2024. Motion hearing held. Plaintiff's motion to extend the temporary restraining order 26 is granted. The TRO is extended to 8/14/2024. Mailed notice

SUMMONS Returned Executed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 8/7/2024, answer due 8/28/2024.

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD for preliminary injunction

NOTICE of Motion by Shawn Anthony Mangano for presentment of motion for preliminary injunction, 31 before Honorable Jeremy C. Daniel on 8/14/2024 at 09:30 AM.

ORDER FOR PRELIMINARY INJUNCTION. Signed by the Honorable Jeremy C. Daniel on 8/14/2024. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction 31 is granted. The plaintiff is hereby 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 located at www.ilnd.uscourts.gov/instructions. Mailed notice.

NOTICE of Voluntary Dismissal by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD ONLY As to Defendant 200

NOTICE of Voluntary Dismissal by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD ONLY as to Defendants 106 and 177

MINUTE entry before the Honorable Jeremy C. Daniel: Status report due on or before 10/15/2024. Mailed notice.

STATUS Report in Compliance with Docket 36 by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

NOTICE of Voluntary Dismissal by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD ONLY as to Defendant 13

MINUTE entry before the Honorable Jeremy C. Daniel: Status hearing set for 12/12/2024 at 9:30 a.m. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: Status hearing held. Plaintiff's dispositive motion is due on or before 1/10/2025; responses are due on or before 1/24/2025; any reply is due on or before 1/31/2025. Court will rule by mail. Mailed notice.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD for summary judgment PURSUANT TO FRCP 56 AGAINST THE IDENTIFIED SCHEDULE "A" DEFENDANTS

NOTICE of Motion by Shawn Anthony Mangano for presentment of motion for summary judgment, [42] before Honorable Jeremy C. Daniel on 1/16/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: In light of the order entered on 12/12/2024 [40], the motion hearing set for 1/16/2025 is stricken. Mailed notice.

PLAINTIFFS STATEMENT OF NON-OPPOSITION TO MOTION FOR SUMMARY JUDGMENT STATEMENT by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

MOTION by Attorney Shawn A. Mangano to withdraw as attorney for HONG KONG LEYUZHEN TECHNOLOGY CO., LTD. No party information provided

NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion to withdraw as attorney[46] before Honorable Jeremy C. Daniel on 2/11/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Plaintiff Hong Kong Leyuzhen Technology Co. Limited ("Plaintiff"), filed a Motion for Leave to Withdraw Shawn A. Mangano as counsel of record for Plaintiff [Dkt. No. 46 ]. After reviewing the Motion and the accompanying record, the Court GRANTS Plaintiff's Motion. IT IS HEREBY ORDERED that: (1) Shawn A. Mangano be withdrawn as counsel of record for Plaintiff; and (2) The Clerk of Court shall remove Shawn A. Mangano from the ECF/NEF service list. Mailed notice.

MINUTE entry before the Honorable Jeremy C. Daniel: The Court sets the plaintiff's motion for summary judgment for argument on August 13, 2025, at 10:00 a.m. The Court intends to address the following issues at the hearing. First, the plaintiff relies on unanswered requests for admission in support of its motion, but Exhibit A (R. 42-4) to the Mangano Declaration (R. 42-3) does not list the defendants' email addresses. Other than paragraph 6 of the Mangano Declaration, there is no evidence that the defendants received the requests for admission. Second, the plaintiff needs to address whether it is proper to serve discovery on a party that has failed to appear in the case. Third, the plaintiff needs to identify record evidence that supports the plaintiff's assertions that the defendants have sold products advertised in connection with the asserted copyrights in Illinois. Fourth, the plaintiff must identify where in the record are the images covered by the copyright registration. Finally, the plaintiff needs to address the propriety of summary judgment, as opposed to default judgment, against a defendant who has not appeared in the case. Mailed notice.

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Katherine Marilyn Kuhn

MINUTE entry before the Honorable Jeremy C. Daniel: Oral argument set for 8/13/2025 at 10:00 a.m. is reset to 01:30 p.m. (TIME CHANGE ONLY) Mailed notice.

SUPPLEMENT to set deadlines/hearings, [49] in Response to Docket 49

ORDER: The plaintiff's motion for summary judgment [42] is denied. All previously sealed entries in this case are unsealed. Status hearing set for September 10, 2025, at 9:30 a.m. Signed by the Honorable Jeremy C. Daniel on 8/14/2025. Mailed notice.

ATTORNEY Appearance for Defendants Ali May Store, BELOVING Cloths Store, Beautiful 7 Store, Chic Beauties, Duo Le Xi Duo Duo Store, Easier for Life Store, Ele-choices Store, Elegent Store, Eternal Esther Store, Fancy Clothing Store, Fashion Women Garment Store, Fashionable Clothes Code Store, Pretty Clothes Store, RE Wearing Store, Rose Apparel Store, RyansJewelry Store, RyansWatch Store, See you 99 Store, To Be Male Universe Clothing Store, YAOOERER Store, You Different Store, Abandon Red Store, Aring Dropshipping Store, Bling Star Store, ClOTHE YOUR LIFE Store, JomooC Store, Valyas Store, WOWKA Store, YAOOERYAO Store, YouYo Store by Adam Edward Urbanczyk

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Abandon Red Store, Ali May Store, Aring Dropshipping Store, BELOVING Cloths Store, Beautiful 7 Store, Bling Star Store, Chic Beauties, ClOTHE YOUR LIFE Store, Duo Le Xi Duo Duo Store, Easier for Life Store, Ele-choices Store, Elegent Store, Eternal Esther Store, Fancy Clothing Store, Fashion Women Garment Store, Fashionable Clothes Code Store, JomooC Store, Pretty Clothes Store, RE Wearing Store, Rose Apparel Store, RyansJewelry Store, RyansWatch Store, See you 99 Store, To Be Male Universe Clothing Store, Valyas Store, WOWKA Store, YAOOERER Store, YAOOERYAO Store, You Different Store, YouYo Store

MOTION by Defendants Abandon Red Store, Ali May Store, Aring Dropshipping Store, BELOVING Cloths Store, Beautiful 7 Store, Bling Star Store, Chic Beauties, ClOTHE YOUR LIFE Store, Duo Le Xi Duo Duo Store, Easier for Life Store, Ele-choices Store, Elegent Store, Eternal Esther Store, Fancy Clothing Store, Fashion Women Garment Store, Fashionable Clothes Code Store, JomooC Store, Pretty Clothes Store, RE Wearing Store, Rose Apparel Store, RyansJewelry Store, RyansWatch Store, See you 99 Store, To Be Male Universe Clothing Store, Valyas Store, WOWKA Store, YAOOERER Store, YAOOERYAO Store, You Different Store, YouYo Store for leave to file excess pages

NOTICE of Motion by Adam Edward Urbanczyk for presentment of motion for leave to file excess pages, [56] before Honorable Jeremy C. Daniel on 9/11/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: The defendants' motion for leave to file excess pages [56] is granted. The motion hearing is stricken. Mailed notice.

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants Beautiful 7 Store, WOWKA Store, Rose Apparel Store, Abandon Red Store, Duo Le Xi Duo Duo Store, Aring Dropshipping Store, Elegent Store, Easier for Life Store, YAOOERYAO Store, You Different Store, BELOVING Cloths Store, ClOTHE YOUR LIFE Store, Pretty Clothes Store, To Be Male Universe Clothing Store, RyansJewelry Store, Eternal Esther Store, Fashion Women Garment Store, RE Wearing Store, Valyas Store, See you 99 Store, YAOOERER Store, Fancy Clothing Store, Ali May Store, Chic Beauties, JomooC Store, Ele-choices Store, Bling Star Store, RyansWatch Store, YouYo Store, Fashionable Clothes Code Store re: Counts II-III, MOTION by Defendants Beautiful 7 Store, WOWKA Store, Rose Apparel Store, Abandon Red Store, Duo Le Xi Duo Duo Store, Aring Dropshipping Store, Elegent Store, Easier for Life Store, YAOOERYAO Store, You Different Store, BELOVING Cloths Store, ClOTHE YOUR LIFE Store, Pretty Clothes Store, To Be Male Universe Clothing Store, RyansJewelry Store, Eternal Esther Store, Fashion Women Garment Store, RE Wearing Store, Valyas Store, See you 99 Store, YAOOERER Store, Fancy Clothing Store, Ali May Store, Chic Beauties, JomooC Store, Ele-choices Store, Bling Star Store, RyansWatch Store, YouYo Store, Fashionable Clothes Code Store to dismiss for lack of jurisdiction

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD for default judgment as to 166 Defaulted Defendants

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [60] before Honorable Jeremy C. Daniel on 9/10/2025 at 09:30 AM.

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Defendants' motion to dismiss [59] is briefed as follows: response is due on or before 10/8/2025; reply is due on or before 10/22/2025. Court will rule by mail. Plaintiff's motion for default judgment [60] is entered and continued to 9/18/2025 at 9:30 a.m. Mailed notice.