2024-cv-08747

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-22508321.

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 Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Heather K. McShain. 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 1-2 regarding declaration[14]

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

MEMORANDUM by Nike, Inc. Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum[19]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 11, motion for electronic service of process 16, and motion for leave to file under seal 3. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 09/30/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Franklin U. Valderrama on 9/26/2024.

Registry Deposit Information Form by Nike, Inc.

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 Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order 24. The Temporary Restraining Order 22 shall now expire on 10/28/2024 at 6:00 p.m. The Court notes for the record that the bond posted in this case is reflected as Docket No. 23, "Registry Deposit Information Form." Mailed notice.

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

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 regarding memorandum in support of motion 29

(Exhibit 1)

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/23/2024, answer due 11/13/2024.

Declaration Of Berel Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion for entry of a preliminary injunction 28. In connection with that motion, plaintiff must serve all Defendants who have not appeared with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before 11/13/2024." If no objections are filed by that date, the Court will consider the motion unopposed by Defendants who have not yet appeared. Plaintiff is directed to file a status report on 11/13/2024 as to whether the preliminary injunction is opposed or not. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding set deadlines, 32

(Exhibit A)

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

STATUS Report per [32] by Nike, Inc.

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction [28] is granted. Enter Preliminary Injunction Order as amended. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 11/15/2024. Mailed notice.

NEW PARTIES: Bengbu City Lan Ying Purification Engineering Co., Ltd., Dongguan Leibeika Trading Co., Ltd., Foshan City Shunde District Pingrong Zhenxuan Trading Firm(Individual Business), Fujian Dadudu Technology Co., Ltd., Fuzhou Platinum Times Trading Co., Ltd., Guangzhou Lucky Intelligent Technology Co., Ltd., Guangzhou Naxier Trading Co., Ltd., Guangzhou Olivia Jewelry Co., Ltd., Guangzhou Panyu Nancun Mangge Shoes Firm (Individual Business), Guangzhou Tuoxin Plastic Products Co., Ltd., Guangzhou Vincent Shoes Co., Ltd., Haining Qiangyi Trading Co., Ltd., Hebei Floating Cloud Trading Co., Ltd., Hubei Wanzhuoli Apparel Co.,ltd, Huzhou Nuobo Import And Export Co., Ltd., Huzhou Yuelan Garment Co., Ltd., Jiangmen City Sunfei Sports Co., Ltd., Jiangxi Maishuo Clothing Co., Ltd., Jiangxi Yangfan Shoes Co., Ltd., Jiaozuo Huatong Shoes Factory, Jinhua Sen Valley Trading Co., Ltd., Jinjiang City Chendai Town Ding Weihan Shoes and Clothing Firm (Individual Business), Jinjiang Great Shoes Tech Co., Ltd., Jinjiang Mingtuojiyuan Trading Co., Ltd., Kingtai Craft Products Co., Ltd., Kuo Xi (xiamen) E-Commerce Co., Ltd., Nanan City Kangmei Town Chiyang Shoes And Clothing Store, Qianshan Leshui Trading Co., Ltd., Qiao Fenghang International Trade Co., Ltd, Qingdao Honrise Trading Co., Ltd., Quanzhou Alganji Trading Co., Ltd., Quanzhou Blue Butterfly Trading Co., Ltd., Quanzhou BM Trade Co., Ltd., Quanzhou Chunqing Sporting Goods Co., Ltd., Quanzhou Doing Trading Corp., Ltd., Quanzhou Easy Trade Technology Co., Ltd., Quanzhou Fengze District Richeer Trading Firm(individual Business), Quanzhou Huake International Co., Ltd., Quanzhou Jiayien Trading Co., Ltd., Quanzhou Jinhong Import And Export Co., Ltd., Quanzhou Joye Sporting Goods Co.,ltd, Quanzhou Lemon Forest Sports Products Co., Ltd., Quanzhou Licheng Dingshuo Trading Co., Ltd., Quanzhou Licheng District Mr. Huang Trading Co., Ltd., Quanzhou Lilu Trading Co., Ltd., Quanzhou Lingyunzhi Electronic Commerce Co., Ltd., Quanzhou Suhuo Trading Co., Ltd, Quanzhou Yinhuilai Trading Co., Ltd., Ruian Jusen Shoes Firm, Shandong Hht International Trading Co., Ltd., Shandong Lemonshe Technology Co., Ltd., Shanghai Xunyu Industrial Co., Ltd., Shangrao Jiahang Clothing Factory, Shantou Chaonan District Chendian Binxing Knitting Underwear Factory, Shantou Chaoyang Oufaner Clothing Co., Ltd., Shenyang Willian Network Technology Co., Ltd., Shenzhen Fenghuanye Technology Co., Ltd., Shenzhen Longgang Yingzi Trading Firm, Shishi City Hushi Trade Ltd, Shishi City Kai Xun Trading Co., Ltd., Shishi City Zileng Tuole Network Clothing Firm, Shishi Dunke Trading Co., Ltd., Wade Group Company Limited, Wenzhou Dongcun E-Commerce Co., Ltd., Wenzhou Huanchuang Shoes Trading Co., Ltd., Wenzhou Quicker Trading Co., Ltd, Wuhu Lush Technology Co.,ltd, Wuping Herui E-Commerce Service Department (Individual Business), Xiamen Chen Weisheng Trading Co., Ltd., Xiamen Haicang District Xiang Juhui Clothing Shop, Xiamen Hwish Import& Export Co., Ltd., Xiamen Skh Trading Co., Ltd., Xiamen Taohaohuo Trading Co., Ltd., Xiamen Xuezhimei Trading Co., Ltd., Xinhua District Yingshang Daily Necessities Firm, Xinyu Sencai Trading Co., Ltd., Yiwu Beicheng Trading Co., Ltd., Yiwu Bowu E-Commerce Firm, Yiwu Dickmon Arts & Crafts Co., Ltd., Yiwu Fenggao Jewelry Co., Ltd., Yiwu Joy Technologies Limited, Yiwu Junqian Trade Co., Ltd., Yiwu Shounuo Trading Co., Ltd., Yiwu Weidu Hair Accessory Co., Ltd., Yiwu Xuye E-Commerce Firm(Individual Business), Yiwu Yelu E-Commerce Co., Ltd., Yulin Xuchen Garment Accessories Co., Ltd., Zhaoqing City Gaoyao District Chunlin Silicone Craft Gifts Co., Ltd., Zhejiang Qixiu Knitting Co., Ltd., Zhongshan Eonshine Textile Craft Co., Ltd., Zhongshan Wantai Crafts Gifts Co., Ltd., Zhongshan Yihe Shoe Industry Co., Ltd. and Zhuji Hongjin Knitting Co., Ltd. added to case caption.

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

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 39

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

(Exhibit 1)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment [39]. Statutory damages are awarded in the amount of $200,000 per each distinct Defaulting Defendant as indicated in the order. Enter Default Judgment Order. Given there are no defendants remaining in this case, the ten-thousand-dollar ($10,000) cash bond, including any interest minus the registry fee, posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns & Crain, Ltd. The Clerk of the Court is directed to return the cash bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain, Ltd., 200 West Madison Street, Suite 2100, Chicago, IL, 60606. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 12/2/2024. Mailed notice.

***Civil Case Terminated.

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendants

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding Default Judgment 43 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding Default Judgment[43] in the amount of $200,000 as to certain defendant