2024-cv-06106

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-22262488.

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 Virginia M. Kendall. Designated as Magistrate Judge the Honorable M. David Weisman. 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.)

ORDER: Local Rule 3.1 requires at the time of filing a case, plaintiff's counsel, or if the case is filed pro se, the plaintiff shall file with the original papers a completed designation sheet (civil cover sheet). No civil cover sheet was submitted at the time of filing this matter. Nike, Inc. is directed to file the Civil Cover Sheet within 14 days of this notification. Signed by the Executive Committee.

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 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)

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 3 - Parts 1-2 regarding declaration 15

Exhibit 3-1

(Exhibit 3-2)

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 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for temporary restraining order 12, motion for miscellaneous relief 17 before Honorable Virginia M. Kendall on 7/24/2024 at 09:00 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 7/24/2024 is reset for 9:30 AM (PLEASE NOTE TIME CHANGE ONLY) which will proceed in Courtroom 2503. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion hearing set for 7/24/2024 is reset for 10:00 AM (PLEASE NOTE TIME CHANGE ONLY) which will proceed in Courtroom 2503. Mailed notice

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 7/24/2024. Plaintiff's Sealed Motion for Temporary Restraining Order 12 is granted and shall remain in effect up to and including 8/7/2024. Sealed Order to follow. Plaintiff's Motion for electronic service of process 17 and Motion for leave to file under seal 3 are granted. Status hearing set for 8/7/2024 at 9:30 AM. Mailed notice

SEALED Temporary Restraining Order signed by the Honorable Virginia M. Kendall on 7/24/2024. Mailed notice

Registry Deposit Information Form by Nike, Inc.

SURETY BOND in the amount of $10,000 posted by Nike, Inc.

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

MOTION by Plaintiff Nike, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction 29

DECLARATION of Marcella D. Slay regarding memorandum in support of motion 30

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction 29 before Honorable Virginia M. Kendall on 8/7/2024 at 09:00 AM.

(Exhibit A)

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/2/2024, answer due 8/23/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

ATTORNEY Appearance for Plaintiff Nike, Inc. by Trevor Christian Talhami

MINUTE entry before the Honorable Virginia M. Kendall. On the Court's own Motion, Motion and Status hearing set for 8/7/2024 is reset for 8/12/2024 at 9:30 AM. Mailed notice.

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

MINUTE entry before the Honorable Virginia M. Kendall. Motion hearing held on 8/12/2024. Plaintiff's Motion for Preliminary Injunction [29] is granted. Order to follow. Status hearing set for 9/23/2024 at 9:30 AM. Mailed notice

PRELIMINARY Injunction Order signed by the Honorable Virginia M. Kendall on 8/12/2024. Mailed notice

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ATTORNEY Appearance for Defendant PAODIKUAI by Steven G Kalberg

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

MOTION by Defendant PAODIKUAI for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer[41] before Honorable Virginia M. Kendall on 8/29/2024 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendant PAODIKUAI's Unopposed Motion for extension of time to answer or otherwise plead [41] is granted. Responsive Brief shall be filed by 9/23/2024. Status hearing is reset for 10/9/2024 at 9:30 AM. Motion hearing set for 8/29/2024 is stricken. Mailed notice

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

ATTORNEY Appearance for Defendant BROKIG by Bole Yuan

ATTORNEY Appearance for Defendant Canghpgin by Erin Kathryn Russell

MOTION by Defendant Canghpgin for extension of time UNOPPOSED FIRST MOTION

(UNOPPOSED) NOTICE of Motion by Erin Kathryn Russell for presentment of extension of time[47] before Honorable Virginia M. Kendall on 9/3/2024 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall: Defendant Canghpgin's Unopposed First Motion For Extension Of Time [47] is granted. Responsive pleading shall be filed by 9/6/2024. Status hearing remains set for 10/9/2024 at 9:30 AM. Motion hearing set for 9/3/2024 is stricken. Emailed notice

MOTION by Defendant BROKIG for extension of time to file answer regarding complaint[1] or otherwise plead (Unopposed)

MINUTE entry before the Honorable Virginia M. Kendall. Defendant BROKIG'S Unopposed Motion For Extension Of Time [50] is granted. Responsive pleading shall be filed by 9/10/2024. Status hearing remains set for 10/9/2024 at 9:30 AM. Mailed notice

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

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 as to Certain Defendants, MOTION by Plaintiff Nike, Inc. for default judgment as to Certain Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment[55]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[56]

Exhibit 1

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment[55] before Honorable Virginia M. Kendall on 10/3/2024 at 09:00 AM.

Exhibit A

MINUTE entry before the Honorable Virginia M. Kendall. Plaintiff's Motion for entry of Default and Default Judgment as to remaining Defendants with the exception of Defendants Brokig and Paodikuai [55] is granted. Enter Order of Default as to remaining Defendants with the exception of Defendants Brokig and Paodikuai. Final Judgment to enter. Motion hearing set for 10/3/2024 is stricken. Mailed notice

FINAL Judgment Order signed by the Honorable Virginia M. Kendall on 9/20/2024. Mailed notice

MOTION by Defendant PAODIKUAI for extension of time to file answer regarding complaint[1] or otherwise respond (unopposed)

NOTICE of Motion by Steven G Kalberg for presentment of motion for extension of time to file answer[61] before Honorable Virginia M. Kendall on 10/3/2024 at 09:30 AM.

MINUTE entry before the Honorable Virginia M. Kendall. Defendant PAODIKUAI's Unopposed Motion for extension of time to answer or otherwise plead [61] is granted. Responsive Brief shall be filed by 10/23/2024. Status hearing is reset for 10/29/2024 at 9:30 AM. Motion hearing set for 10/3/2024 is stricken. Mailed notice

MOTION by Defendant BROKIG for extension of time to file answer regarding complaint[1] Unopposed, Second

MINUTE entry before the Honorable Virginia M. Kendall. Defendant BROKIG'S Unopposed Motion For Extension Of Time [64] is granted. Responsive pleading shall be filed by 10/8/2024. Mailed notice

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

MOTION by Plaintiff Nike, Inc. for Entry of an Agreed Asset Restraint Order as to Defendant No. 5 Joint

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[67] before Honorable Virginia M. Kendall on 10/8/2024 at 09:30 AM.

AGREED Asset Restraint Order as to Defendant No. 5 signed by the Honorable Virginia M. Kendall on 10/3/2024. Motion hearing set for 10/8/2024 is stricken. Mailed notice

SATISFACTION of Judgment regarding order[60] in the amount of $150,000 as to certain defendant

MOTION by Defendant BROKIG for extension of time to file answer regarding complaint[1] Unopposed, Third

MINUTE entry before the Honorable Virginia M. Kendall. Defendant BROKIG'S Unopposed Motion For Extension Of Time 71 is granted. Responsive pleading shall be filed by 10/23/2024. Mailed notice

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

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing set for 10/29/2024 at 9:30 AM will proceed in Courtroom 1725 (PLEASE NOTE CHANGE OF COURTROOM). Mailed notice

ATTORNEY Appearance for Plaintiff Nike, Inc. by Thomas Joseph Juettner

MINUTE entry before the Honorable Virginia M. Kendall. Status hearing held on 10/29/2024. Plaintiff's Counsel advised they have settled with remaining Defendants. Case is dismissed. Civil case terminated. Mailed notice

FULL SATISFACTION of Judgment regarding order 60 in the amount of $150,000 as to certain defendant