2024-cv-03135

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 405, receipt number AILNDC-21872924.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

Notice of Claims Involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Harley-Davidson Motor Company, 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 Adraea M. Brown regarding memorandum in support of motion 12

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 3 - Parts 1-6 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, 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 temporary restraining order 11, motion for leave to file 3, motion for miscellaneous relief 16 before Honorable Elaine E. Bucklo on 5/1/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal 3 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 11 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 16 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 5/15/2024, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 5/8/2024. 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 of the expiration of the TRO. 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. The case is set for a status hearing on 6/17/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 6/10/2024 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 5/1/2024. Mailed notice.

Registry Deposit Information Form by Harley-Davidson Motor Company, Inc.

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

Surety BOND in the amount of $ $10,000.00 posted by Harley-Davidson Motor Company, Inc.

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction as to certain Defendants

(Exhibit A)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction 23

Declaration of Marcella D. Slay

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 23 before Honorable Elaine E. Bucklo on 5/15/2024 at 09:45 PM.

(Exhibit A)

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/8/2024, answer due 5/29/2024.

Declaration of Trevor C. Talhami

(Exhibit A)

Corrected NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[23] before Honorable Elaine E. Bucklo on 5/15/2024 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction as to certain defendant [23] Nos. 10-82 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Adraea M. Brown [15] and the TRO [21]. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 5/15/2024. Mailed notice.

NEW PARTIES: Dongguan Forever Emblem & Badge Craft Co., Ltd., Dongguan Qianjiayi Garment Co., Ltd., Dongguan UTC Accessory Co., Ltd., Fujian Ql Metal Fiber Co., Ltd., Guangzhou Jinxiuxing Jewelry Co., Ltd., Shenzhen Bao'an Fuyong Kangfeng Embroidery Factory, Shenzhen Skywing Leather Gifts Co., Ltd., Zhejiang Fujia Crafts Co., Ltd., Zhengzhou Anbu Safety Industrial Co., Ltd., 6046, A1UWU6IY8D6F3E, A2THZKMO9JJZVA, A3C91QJKHSM1A5, AiYaJun, AOPV0GX3OIJ4L, Aprtimehi, ayubaihuo, BLOSDREAM, DingXiangXianFuFuHuoGuoDian, elegant threads, Fanlucky, Guangzhou Yule E-commerce Co., LTD, guangzouminanshangmaoyouxiangongsi, haerbinshishengkaiwangluokejiyouxianzerengongsi, Happy DJ S, Happy-shopping, HaweDecor, HD-US-Store, hengshuishizhajunyunshangmaoyouxiangongsi, hyhtsmyxgs, jianjizhouquhaolekuajingdianshangltd, KunXiuSong, Legou, Liem nguyen123, LINFUEN, Little bags accessories, Lucyy us, Miruan, Nexpress, Nghiem Phan, NieJunLi's Shop, oukese, Pro Flag Depart (ENMOONVagairKasflag QiQ, putianshilichengqucaoyouruomaoyiyouxiangongsi, QMNhanm466, SeraphinaYY, Shanghai Story Official Store, Squirrelwood, WANWANJIA, wzxdd, xiaoxiazhenxuanmaoyi, XunHan, Yixda-us, ZGUANGF, zhai117539guo030111wei, zhengzhouqinguanshangmaoyouxiangongsi, ZHUOYUJIA, burberyqq004, cml005, cml006, cyclingglasses_x, dhtshirtlq303, discountrange, funwholesale, gold8, goodshighqualityq1, hmx02, hxm01, mabahui015, maria113, mengtuo202204, outdoors28, perfecttop0, perfecttop7, plussize8, suecy, wangx00, zcdsk, aaquarius, high-soft, yingxiong2024yang and HHGoods added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction[33]

Declaration of Marcella D. Slay

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[33] before Honorable Elaine E. Bucklo on 6/5/2024 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/29/2024, answer due 6/19/2024.

Declaration of Trevor C. Talhami

Exhibit A

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for entry of preliminary injunction as to certain Defendants [33] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Adraea M. Brown [15] and the TRO [21]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 6/4/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

STATUS Report Pursuant to 20 by Harley-Davidson Motor Company, Inc.

MINUTE entry before the Honorable Elaine E. Bucklo: MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff are engaged in settlement negotiations with a number of defendants. Status hearing is reset for 7/22/2024 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 7/15/2024. The court will enter an order in response to the status report. Mailed notice. (jn,)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, [43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, [43] before Honorable Elaine E. Bucklo on 6/26/2024 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Defendants Happy DJ S, guangzouminanshangmaoyouxiangongsi by Adam Edward Urbanczyk

MOTION by Defendants Happy DJ S, guangzouminanshangmaoyouxiangongsi for extension of time

MINUTE entry before the Honorable Elaine E. Bucklo: Parties to take note of Judge Bucklo's motion call practice posted on her page at www.ilnd.uscourts.gov. Defendants guangzouminanshangmaoyouxiangongsi and Happy DJ S's motion for extension of time to respond to Plaintiff's complaint [48] is granted to 7/12/2024. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment [43] is reset for 7/22/2024 at 9:45 a.m. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

STATUS Report Pursuant to 42 by Harley-Davidson Motor Company, Inc.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment [43] is granted. Enter Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff or its counsel, Greer Burns & Crain, Ltd. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 7/24/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order 54 in the amount of $100,000 as to certain defendants

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Harley-Davidson Motor Company, Inc. to Greer Burns & Crain Ltd 300 South Wacker Drive Suite 2500 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7784 06. (Text entry; no document attached.)

RETURN of U.S. Post Office Receipt, article no. 0710 5270 0579 7784 06.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

FULL SATISFACTION of Judgment regarding order 54 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 54 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 54 in the amount of $100,000 as to certain defendant