2024-cv-08188

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 405, receipt number AILNDC-22451697.

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 1 - Parts 1-2 regarding complaint[1]

MOTION by Plaintiff Dyson Technology Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dyson Technology Limited

Notice of Claims Involving Patents by Dyson Technology Limited

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Lawrence J. Crain

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 1).

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 Dyson Technology Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Dyson Technology Limited 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)

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion 13

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 2 - Parts 1-2 regarding declaration 15

Exhibit 2-1

(Exhibit 2-2)

MOTION by Plaintiff Dyson Technology Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Dyson Technology Limited 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 temporary restraining order 12, motion for miscellaneous relief 17, motion for leave to file 4 before Honorable Jorge L. Alonso on 9/18/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [4] [12] [17] are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $85,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 9/18/24 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 9/17/2024. Notice mailed by Judge's staff

Registry Deposit Information Form by Dyson Technology Limited

SURETY BOND in the amount of $85,000 posted by Dyson Technology Limited (Document not scanned)

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

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction[25]

Declaration of Justin T. Joseph

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction[25] before Honorable Jorge L. Alonso on 10/1/2024 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/26/2024, answer due 10/17/2024.

Declaration of Andrew D. Burnham

Exhibit A

RESPONSE by Jiale Zhao to MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants [25]. (Exhibits) (Received via pro se email on 9/27/24.)

MOTION by Plaintiff Dyson Technology Limited to strike Defendants' Response to Plaintiff's Motion for Preliminary Injunction [29] or in the alternative, Compel Defendants to Obtain U.S. Counsel

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion to strike[30] before Honorable Jorge L. Alonso on 10/3/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Motion hearing set for 10/1/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction as to certain Defendants [25] is granted. Enter Preliminary Injunction Order. Plaintiff 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 at www.ilnd.uscourts.gov. For the reasons stated on the record, Plaintiff's Motion to strike Defendants' response to Plaintiff's motion for preliminary injunction [29] or in the alternative, compel Defendants to obtain U.S. counsel [30] is granted. Defendants Dutchman (No.61) and Pinsurad (No. 76)'s Response to Plaintiff's motion for preliminary injunction [29] is stricken. Motion hearing date of 10/3/24 is stricken. Telephonic status hearing set for 11/14/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/2/2024. Notice mailed by Judge's staff

NEW PARTIES: Dongguan EFA Co., Ltd, Dongguan Yuhui Electric Appliance Co., Ltd., Guangzhou Hotwind Electronics Co., Ltd., Hainan Liangmi International Trade Co., Ltd., Market Union Co., Ltd. (1), Ningbo Youshow Sports Co., Ltd., Shenzhen Blue Eagle E-Commerce Co., Ltd., Shenzhen Chen Man Technology Co., Ltd., Shenzhen Guanghaoming Technology Co., Ltd., Shenzhen Huayi Technology Co., Ltd. 1, Shenzhen Ifine Technology Company Ltd., Shenzhen Kasitong Technology Co., Ltd., Shenzhen Lunata Technology Co., Ltd., Shenzhen Victory Technology Co., Ltd., Shenzhen Weikete Electronics Co., Ltd., Shenzhen Xing Da Circuits Technology Co., Ltd., Shenzhen Yagelong Technology Co., Ltd., Shenzhen Yaxinlong Technology Co., Ltd., Vastrade Manufacturing Inc., Xuzhou Dipunuo Import And Export Trading Co., Ltd., Xuzhou Longmeika Technology Co., Ltd., Yiwu Goplay International Trading Co., Ltd., Yiwu Sihong Technology Co., Ltd., Yiwu Yinba Daily Necessities Firm, Zhuji Yinuo Trading Co., Ltd., 51BEST, FHF-AMZ, Lulin Department Store, RonxRaepper, ZhuCheN, cinitt, cjbaqi, dchluoyun, denda, dhgatewig, dkfffddf4671, electronics0316, enlai_xin1, flying_queen019, gidnf1611, heijue03, ning4323, shirting_fashion, shu07, sjjlhome, swccz, tonightt, Decform, Giimallus, hstoyhomes, jingyi02, longyongpong, NAMMA-07, okwisa, tpf341, wannabe1111, weilai18, daixiaolindai, dazhanhongtudianpu, dongwanshipanweixinxikeji, Dutchman, EZIHOMELIFE, Fory Choice, foshanshihaobangyeshangmao, givganer, guangzhoubaiqiaozhuangxiu, guangzhourongdadianshang, guangzhoushibailandijia, guxhytr, ikhdechyersb, jinshan, Linda's Chinese Tea Cup, Many nice Deal, maomingningzuocanyin, phospheye, Pinsurad, Running Girl, Sun reputation Toys, TYHZY, Wenstonbeauty, xuzelailai, XXiaoju, zhaoliangfashangmao, Zhiding co., ltd and zhdajdhadkfhkdj added to case caption.

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendants

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendants

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction[37]

Declaration of Justin T. Joseph

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction[37] before Honorable Jorge L. Alonso on 10/22/2024 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/17/2024, answer due 11/7/2024.

Declaration of Andrew D. Burnham

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/22/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's motion for entry of a preliminary injunction as to certain Defendants [37] is granted. Enter preliminary injunction order. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/29/2024. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Status hearing held and continued to 11/21/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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.Notice mailed by Judge's staff

MOTION by Plaintiff Dyson Technology Limited to approve consent judgment as to certain Defendants (Agreed)

Exhibit A

MOTION by Plaintiff Dyson Technology Limited for entry of default, MOTION by Plaintiff Dyson Technology Limited for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for entry of default, motion for default judgment[49]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[50]

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment[49], motion to approve consent judgment[48] before Honorable Jorge L. Alonso on 11/21/2024 at 09:30 AM.

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Agreed Motion for entry of a consent judgment as to Defendants nos. 64, 83 and 84 [48] is granted. Enter Consent Judgment. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [49] is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

CONSENT Judgment. Signed by the Honorable Jorge L. Alonso on 11/21/2024. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 11/21/2024. Notice mailed by Judge's staff

MAILED patent report with a certified copy of the minute order 53, consent judgment 54, and final default judgment order 55 dated 11/21/2024 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 55 in the amount of the Judgment Amount as to certain defendants

FULL SATISFACTION of Judgment regarding order 55 in the amount of the Judgment Amount as to certain defendant

FULL SATISFACTION of Judgment regarding order 55 in the amount of the Judgment Amount as to certain defendant

FULL SATISFACTION of Judgment regarding order 55 in the amount of the Judgment Amount as to certain defendant