2024-cv-03282

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21890819.

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

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

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 1-7 regarding declaration 14

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

(Exhibit 3-7)

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)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [11] is granted. Plaintiff's motions for leave to file under seal [3] and for electronic service of process [16] are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/29/2024. Mailed notice

Registry Deposit Information Form by Nike, Inc.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

SURETY BOND in the amount of $110,000.00 posted by Nike, Inc. (Document not scanned). (jn,) Modified on 5/3/2024.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A. (evw,)

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[24]

DECLARATION of Marcella Slay regarding memorandum in support of motion[25]

Exhibit 1

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

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 24 is taken under advisement. Any objection or response is due before 5/14/24. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement, by 5/10/24, the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before May 14, 2024. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 28

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [24] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 5/22/24 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/15/2024. Mailed notice

NEW PARTIES: All Stylish Store, Ammmlyy Store, factory yi Store, hazel102 Store, HUANG4 Store, Malavia Store, Wvzw Official Store, Ali_Welcome Store, An Amazing Shoe Store, Angel Light Store, Baby Xu Store, BeforeSunset Store, Change Yourself Store, CHANGZHENG369 Store, Cow, cow, Cow Store, Dance of Wilt Store, DESAI Store, Diana Home Decor Store, Fashionable Wooden House Store Store, Global Smart Home Store, GoodJop Store, Happy Home Textile Store, Heliwey Lighting Store, High-Quality SPORTS SHOES Store, HUOTA Official Store, HZYVJE Baby Kids Shoes Store, JINXUAN Men Boots Store, Magic11 Store, MaiJiaKa Specialty Store Store, MINYA Shoes Store, NHneom Store, Panda Sports Fashion Store, PHOENIX Fashion Wear Store, Plate Art Store, Premium Goods Store, qizi001 Store, Runner C Store, Shop1102306890 Store, Shop1102330059 Store, Shop1102347341 Store, Shop1102890950 Store, Shop1102939556 Store, Shop1103153240 Store, Shop1103330281 Store, Shop1103614394 Store, Shop3861034 Store, Shop4401067 Store, Shop5478103 Store, Shop911303147 Store, TRILEINO Speciality Store, YUPINJIA Shoes Store, changhaitao youth, Custom Football Sneakers, fangzu, gouguangyubaihuoshang, infinite world, lcl small store3, wangtianruishop, zhouxinbaihuo, ZhuCangShangMaoYouXianGongSi, zyili shop, a15859514551, aquanzhou_store, ashanghai_store, awith_shops, babyshoes1688, chinastore08, clogogogo, clothingwholesale12, corteiz25, crown_shops, designersneakers, fanaticshopping, fashion_shoes12, floyd2323, hisneaker_yy, jialidanna888, kfc_clothes, llmm01, mr_wardrobe011, mzmzby, nb_shoes, ogdsneakers, shoes_earnest, sole_supremacy, suifengpiao18, totwo4, unique_shoe_city, vipshoes66, xuebi500, yeezyshoes451, AoSong, gaojistor666, MOI Lighting, nuek55, S.steeljewelryfactory, xurongban, NagiworkzDoll, dk.sneakers_01, kickfam33, roj5532, setesteaukeu, store66888, xclub_kick, chinashoesfactory, dafgsdfo2u, wholesaleandretail6, Chao Shi Commerce Co., Ltd, Zenoluxe E-commerce Co., Ltd and ZWLDDP added to case caption.

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/22/2024, answer due 6/12/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 33 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 92 and 96 are dismissed from this case. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 35 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 108 and 110 are dismissed from this case. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 37 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 54 is dismissed from this case. Mailed notice

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

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 40

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

(Exhibit 1)

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 40 is taken under advisement. Any objections or responses are due by 6/27/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 6/20/24. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, set motion and R&R deadlines/hearings, 43

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 40 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 7/1/2024. Mailed notice

NOTICE of Removal of Material from the Custody of the Clerk's Office by Nike, Inc. (Received at the Intake Counter on11/21/24.)

FULL SATISFACTION of Judgment regarding order[46] in the amount of $175,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [48], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 109. Mailed notice