2024-cv-03639

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-21932291.

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 Andrea R. Wood. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2). (jcc,)

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 3-8 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)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 11, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 16 are set for a telephonic motion hearing on 5/14/2024 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 5/14/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint [2], and (2) Exhibit 3 - Parts 3-8 [15]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 5/14/2024 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 5/28/2024 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 5/14/2024. Mailed notice

Registry Deposit Information Form by Nike, Inc.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A.

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

MOTION by Plaintiff Nike, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Nike, Inc. in support of extension of time[25]

DECLARATION of Marcella Slay regarding memorandum in support of motion[26]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 25 is granted. The Court finds good cause to extend the temporary restraining order an additional 14 days to 6/11/2024. Telephonic status hearing set for 5/28/2024 is stricken and reset for 6/11/2024 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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

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 31

DECLARATION of Marcella D. Slay regarding memorandum in support of motion 32

(Exhibit 1)

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/6/2024, answer due 6/27/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 6/11/2024. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction as to certain defendants [31] is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2], (2) Exhibit 3 - Parts 3-8 [15], and (3) the sealed temporary restraining order [23]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 7/25/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 6/11/2024. Mailed notice

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[35]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[36]

Exhibit 1

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/18/2024, answer due 7/9/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

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

NEW PARTIES: Ali Printech (Yan Tai) Co., Ltd., Chongqing Huayuangou Technology Co., Ltd., Dongguan Sborn Supply Chain Co., Ltd., Foshan Xincheng Electronic Technology Co., Ltd., Foshan Yuhui Trading Co., Ltd., Fuzhou Gifting Trading Co., Ltd., Guangzhou Kaili Carpet Co., Ltd., Guangzhou Qijun Digital Technology Co., Ltd., Guangzhou Xiansu Communication Technology Co., Ltd., Hangzhou Tuhe Commerce Co., Ltd., Huian County Huang Tang Huangyunhong Shoes Clothing Business Department, Hunan Weimin Business Service Co., Ltd., Jinjiang Chuzhi Trading Co., Ltd., Kunshan Hiicoins Technology Co., Ltd., Ningbo Goldmore Industrial Co., Ltd., Quanzhou Jc Sports Products Co., Ltd., Quanzhou Jinxing Trading Co., Ltd., QUANZHOU KICK GROUND FOOTWEAR CO.,LTD., Quanzhou Maohuang Trading Co., Ltd., Quanzhou Oushiyi Trading Co., Ltd., Quanzhou Shike E-Commerce Co., Ltd., Quanzhou Topsion Imp. & Exp. Trading Co., Ltd., Shandong Hht International Trading Co., Ltd., Shanghai Haofan Industrial Co., Ltd., Shenzhen Hezi Information Technology Co., Ltd., Shenzhen JJX Technology Co.,Ltd, Shenzhen Kaili Brand Co., Ltd., Shenzhen Rebow Technology Co., Ltd., Shenzhen Zamfun Garment Accessories Co., Ltd., Tianjin Qingnan Carpet Co., Ltd., Wuhan Xianbang Trading Co., Ltd., Yiwu Tengyu Shoe Factory, Yiwu Xingqi Import & Export Co., Ltd., Zhengzhou Litsign Optronic Technology Co., Ltd., Zhongshan Heyang Gift And Craft Co., Ltd., Boys Girls Basketball Shoes, Fashionable And Exquisite Store, Fly FASHION Store, Fly Shop Store, Helongsheng Store, hyg666888 Store, Original Football Shoes Store, Panda flagship Store, Shop1102907425 Store, Vicky sporting goods Store, Xuefu1608 Store, Yamana factory Store, DingSenZhong1986, DongXinHua, JIAXINXIEFU, MengNi, PoFed Anime Product, wangjiaweishop, Zhengzhouhecushangmaoyouxiangongsi, aigogo2520, an925, anhebags_top01, bff38_shoes, bm7xi, ccfs2000, dh__sneakers, dunksb10, fashionleisure21, fes_store001, freeshipping_shops, goat_shoes, goats, ji_shoes, jordanforsale, ka_shoes, kha9505, lovesshoping, luckysneakers4, luxury_sock_shoes, luxuryshoes_club, lwq1998, lzp8618, macai, meihua977 Store, midian13, minguwu_fashion, moreclothes, nanfang13_shoes, newstylestore066, nice_brand_shoes, nicesize Store, pretty_shoes6106, sbd_sneakers001, shoesaaaaa, shoestars, taopinhui, tnt33_shoes, wheat688, xifang7_shoes, kidscovershop, miniature.world.144, yzyz369, 88luckyshoes, barefoot168, fashion_shoes8888, flippedshoes888, mfankicks, nnscny, pollypolly_2334, rensensen8, tayler_66888, ua_baksss, chinese_suppliers, San yuan qi xing trade, eraofshoe.com and shop77.com added to case caption.

NOTICE of Voluntary Dismissal by Nike, Inc. as to 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[43]

Exhibit 1

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

Exhibit 1

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 7/25/2024. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 43 is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 7/25/2024. Mailed notice

FULL SATISFACTION of Judgment regarding order 48 in the amount of $500,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 48 in the amount of $500,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 48 in the amount of $500,000 as to certain defendants

NOTICE of withdrawal of bond 24 by John Summerfield