2024-cv-03084

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21867638.

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

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

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

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 Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2).

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 1-9 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

(Exhibit 3-9)

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)

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 16 are both granted. Plaintiff's motion for entry of an ex parte temporary restraining order 11 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Preliminary injunction hearing is set for 5/6/2024 at 8:50 AM. The following call-in number will be used for the hearing: 888-684-8852, access code 746-1053. Any motion for preliminary injunction or motion to extend the TRO is to be filed by 5/2/2024. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 4/22/2024.

Registry Deposit Information Form by Nike, Inc.

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

SUMMONS Issued as to Defendant The Partnerships And Unincorporated Associations Identified On Schedule A

ATTORNEY Appearance for Defendant Rich Supply by David Silver

MOTION by Plaintiff Nike, Inc. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[25]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 5/2/2024, answer due 5/23/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of a preliminary injunction as to certain defendants is granted 25. Enter Preliminary Injunction Order. The telephonic hearing set for 5/6/2024 is vacated. The case is set for a telephonic status hearing on 7/8/2024 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 980-394-33. Plaintiff is directed to file a status report on 7/1/2024. Law Firm Greer, Burns and Crain, Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 5/3/2024. Mailed notice.

NEW PARTIES: Dongguan B.Bontic Color Printing Co., Ltd., Fujian Quanzhou Goethewei Shoes Co., Ltd., Fuzhou Zhichen Chuangrun Trading Co., Ltd., Guangzhou Panyu Nancun Mangge Shoes Firm (Individual Business), Henan Luoyang Spotlight Textile Co., Ltd., Luoyang Panfeng Shoes Co., Ltd., Quanzhou Tianhe Star Import And Export Trade Co., Ltd., Shenzhen Jiji Clothing Co., Ltd., Shishi Bangyang Trading Co.,ltd., Wenzhou Muenjoy Trading Co., Ltd., Wenzhou Ouguang Trading Co., Ltd., Xiamen Mingda Trading Co., Ltd., Yupao (Quanzhou) International Trade Co., Ltd., Zhangzhou Xiangcheng Danxing Trading Co., Ltd., Action Power Store, AE Exquisite Home Store, Ascend Selected Store, Babe Love U Store, BEABUKI Official Store, Camel Men's Store, Childers Store, CustomNeonSign Factory Store, CuteLoves Store, Daily Goods Supplier Online Store, EOENKKY Trendy Shoes Store Store, Fashion Shoes Factory Store, Fashion Zone Store, gymboree1 factory Store, Heliwey Led Neon Sign Store, HJSUNFORYOU Store, HomEarl Store, JITUUE FAS Store, Minfei Jewelry Store, Neep Online Store, Neon Sign Store, Pitrianto Official Store, QDance Store, Safety Shoes Factory Direct Store, Shop1102576060 Store, Shop1102603293 Store, Shop1102658553 Store, Shop1102669049 Store, Shop1102727726 Store, Shop1103337097 Store, Shop1103430342 Store, Shop1103570108 Store, Shop1103623872 Store, Shop5619087 Store, Taidhd Home Textiles Store, warm HOME curtains Store, guanglegeguang, HaloHorus Athletics Shop, Haowind, hezeshimudanquqiangxinwujinbaihuodian, ihtha, JISHUNFA, Kcutteyg, leijinhuangdianzishangwuyouxiangongsi, LEYJOKE, Lulizhou xiao dian, Rich Supply, Rrosseyz, sports-90%, Valueon hats, XiaWenJun1970, Z1y2i0X6EN1c4h6i, zhanyuxishangmaoyouxiangongsi, ajjordan1, allgarment, brand_sport_leading, childrensgrocerstore, designerdawei, foot_locker01, goalgoalgoal, good_sneakers996, huataidianchi, jiangzeming, kidsjodan1, kingofshoes, pinmiao40, popularsportsstore, prada1sleeve, shoewholesale2288, sneaker8088, sourcesoso, tuo05, xstocks, youngone0784, ekelin-71, gewenstore, gwen123, jiangjun1216, kafeico, linlinc_19, lion1234, lokshop2010, mens_style798, pisen8, yidaiyil669, yiyunxi_18, yngdgg, zefy_96, zhiyxuanxuan789, zizwar_16, ceciliasoe29207, hy_sneaker, yi.seven, Cathalem Co. Ltd, HICOOER INC, Ptetnvg, TMKBGHML, Vinsonshop, hotkicks.cc, jordanairs.com, willsneakers.net, CreateaneighbortocatchhR, HardyPamelaeUnVsS, luzeben6086, manufacturer.shoes, MiTangBANGYUNsM, OliveBernicemJbJ, Ronalddf, SigridMaricoiTvPw and zhaozhiqiang86408 added to case caption.

ATTORNEY Appearance for Defendant Valueon hats by Timothy Alan Duffy

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Valueon hats

MOTION by Defendant Valueon hats to Dissolve or Modify Preliminary Injunction

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: Response to motion by defendant Valueon hats to dissolve or modify preliminary injunction is to be filed by 5/14/2024; reply to response is to be filed by 5/17/2024. Telephonic motion hearing, unless deemed unnecessary by the Court, is set for 5/22/2024 at 9:15 AM, using call-in number 888-684-8852, access code 746-1053.

MOTION by Plaintiff Nike, Inc. to Extend Briefing Schedule [33] Agreed

DECLARATION of Justin R. Gaudio regarding motion for miscellaneous relief[34]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Matthew F. Kennelly: Agreed motion to extend schedule [34] is granted. Response to motion by defendant Valueon hats to dissolve or modify preliminary injunction is to be filed by 5/21/2024; reply to response is to be filed by 5/28/2024. Telephonic motion hearing is reset to 6/6/2024 at 9:05 AM, using call-in number 650-479-3207, access code 980-394-33.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 5/17/2024, answer due 6/7/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendants

MINUTE entry before the Honorable Matthew F. Kennelly: The motion by defendant Valueon hats to dissolve or modify the preliminary injunction [32] is denied as moot in light of plaintiff's dismissal of its claims against that defendant. The motion briefing schedule and the hearing date of 6/6/2024 are vacated. All other dates and deadlines set by the Court remain as-is.

NOTICE of Voluntary Dismissal by Nike, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Nike, Inc. as to Certain Defendants

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

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default [44] is granted. Enter Final Default Judgment Order. Any hearing dates before this Court are stricken. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 6/14/2024. Mailed notice.

MAILED trademark closing report with certified copies of orders dated 6/14/24 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order[48] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[48] in the amount of $100,000 as to certain defendant

NOTICE of Removal Material from the custody of the Clerk's Office by Justin R. Gaudio of the firm Greer, Burns & Crain, Ltd. by Plaintiff regarding Bond, 23.