2024-cv-05529

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-22199211.

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 Keri L. Holleb Hotaling. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

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 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Joe Pallett regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

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)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-6 regarding declaration 15

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

MINUTE entry before the Honorable Andrea R. Wood: This matter comes before the Court on 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 [12], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16]. Having reviewed the motions and supporting documentation in chambers, the Court grants 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 [12], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16]. Enter Sealed Temporary Restraining Order. The Clerk 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 1-6 [19]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 11:00 a.m. on 12/23/2024 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 1/6/2025 at 1:45 PM. 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 (650) 479-3207 and the access code is 1808131170. 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 12/23/2024. Mailed notice

Registry Deposit Information Form by Nike, Inc.

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

SURETY BOND in the amount of $ 10,000.00 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 24

DECLARATION of Marcella D. Slay regarding memorandum in support of motion 25

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 24 is granted. The Court finds good cause to extend the temporary restraining order through 1/21/2025 pursuant to Fed. R. Civ. P. 65(b)(2). Any motion for a preliminary injunction must be filed by 1/20/2025. Telephonic status hearing set for 1/6/2025 is stricken and reset for 1/21/2025 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 (650) 479-3207 and the access code is 1808131170. 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

MOTION by Plaintiff Nike, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[28]

Declaration of Marcella D. Slay

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/15/2025, answer due 2/5/2025.

Declaration of Berel Y. Lakovitsky

Exhibit A

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 1/21/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [28] 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 1-6 [19], and (3) the sealed temporary restraining order [21]. 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 2/26/2025 at 10:15 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 (650) 479-3207 and the access code is 1808131170. 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 1/21/2025. Mailed notice

NEW PARTIES: A2K3H7VY9JM7JB, A3W27GD0FUCXBL, ALBXGT7FJNCPG, AUD2JFF48OPDK, cucumyelo, GOSBLUE, GuangZhouJinWangShangMaoYouXianGongSi, HEYHALIFE, JB'S Store, maotiezhengshangmaoyouxiangongsi, Mother's Day Memorial Day Independence Day Deals, rongyadianzi, tongshanxianwangbianlinmaoyiyouxiangongsi, weifangyuanqingqishangmaoyouxiangongsi, zengyuansoqiqw, zhengjie9833, Boost 700 Runner, designermenswear277, dh_runnersneaker, factory footwear shoes, favourite sneakers, lhqianlaiqi, perfectvalue11, topapparel00, ttxsba, cfwoze, custom-any jersey, erchic2, fashion-store0511, Fashionuprising-7, guaig76, henzh-53, hkshop-06, HSymmind, kcewccq, liuzhongyue, meujora1, rangy_83, tn-1257, tuaegmwa, uros-7030, valor_threads, wolove1bei, xina955, xixiwang6677, yangli-001, yiwotgsdwet, ag_shoes89, coraroc0, fashion.player.tide6, hotsneakers888, jjcarpenter26, maxmu.w, nilka_melendez, poofactoryclub, quality1shop1, xyzkicks.go, iszeyu, Iveson Trend, Bessyn, Couture Elegy, FH Store, GTHHNBMM, Himmake, James Cabrera store, jinanyunlaihaowangluokeji, Lanluoyi, LIhncine, lizaoshangmao, LZCM, Mylike Clothing, ourukeji, ugeucsd, Yan Gang Commerce Co., Ltd, Yaohua, Zhishanbh, b2ckicks.com, coolkick.store, hypeboosts.ru, momkok.ru, omgow23.ru, shoesreps.org, yslstore.com, baijiahao3749, DizhiyuanrenyN, hanguozhen6254, HUANGMEIYING, jiaankui9164, Prinkar, wenxinhua1234, xuyurong6478, yangmen0845, yangrui9091 and yupei4404 added to case caption.

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

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

MOTION by Plaintiff Nike, Inc. for entry of default, 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 36

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 37

(Exhibit 1)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining Defendants 36 will be heard at the telephonic hearing set for 2/26/2025 at 10:15 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. 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 (650) 479-3207 and the access code is 1808131170. 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 certain defendant

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 2/26/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [36] is entered and continued. By 2/28/2025, Plaintiff shall file a supplement to their motion for default that includes a chart listing the defendants that remain in the case, as well as the amount of funds restrained for each defendant. Plaintiff is granted leave to file the supplement under seal. Telephonic status hearing set for 3/12/2025 at 10:15 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 (650) 479-3207 and the access code is 1808131170. 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 DOCUMENT by Plaintiff Nike, Inc. Plaintiff's Supplement to Motion for Entry of Default and Default Judgment as to all remaining Defendants

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/12/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [36] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 3/14/2025. Mailed notice

MAILED Trademark report to Patent Trademark Office, Alexandria VA