2024-cv-09265

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-22546202.

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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Maria Valdez. 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.

AMENDED complaint by Nike, Inc. against quality_shoes001 and the Individuals and Entities Operating quality_shoes001 and terminating The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Nike, Inc. Amended Schedule A regarding amended complaint, 13

MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 10/25/2024 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the attached status report requirements by 10/17/2024. Plaintiff must still file the report even if Defendants have not responded to requests to craft a joint report. If not all Defendants have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice

MOTION by Plaintiff Nike, Inc. for discovery Expedited

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)

STATUS Report Initial per 15 by Nike, Inc.

MINUTE entry before the Honorable Edmond E. Chang: The pending motions are under advisement. The tracking status hearing of 10/25/2024 is reset to 11/01/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Mailed notice. (jn,)

ORDER signed by the Honorable Edmond E. Chang. In light of the good cause shown to obtain early discovery and to serve process electronically given the online platform, the motions 16 17 to do so are granted. The motion 3 to seal is terminated as moot. The status hearing of 11/01/2024 is reset to 12/13/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 12/06/2024, or the Plaintiff shall file one if the Defendant has not appeared. Mailed notice.

SUMMONS Returned Executed by Nike, Inc. as to quality_shoes001 and the Individuals and Entities Operating quality_shoes001 on 11/13/2024, answer due 12/4/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Edmond E. Chang: In light of the answer deadline of 12/04/2024, if the Defendant does not respond to the complaint on time, then the Defendant is deemed to be in default, and the Plaintiff shall file a default judgment motion for a sum certain on 12/06/2024 instead of a status report. If the Defendant does respond on time, then the parties shall file the joint initial status report on 12/06/2024. Emailed notice

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[25]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[26]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment[25] before Honorable Edmond E. Chang on 12/12/2024 at 08:30 AM.

Exhibit A

MINUTE entry before the Honorable Edmond E. Chang: In light of the absence of a timely answer, the motion for default judgment 25 is granted in large part. Judgment entered in favor of the Plaintiff and against the Defendant in the amount of thirty-five thousand dollars ($35,000). Given the willfulness established by the default, a permanent injunction will be entered. A separate AO-450 judgment shall be entered. The status hearing of 12/13/2024 is vacated. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 12/10/2024. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 12/10/2024. Emailed notice

MAILED trademark report with certified copies of the minute order dated 12/10/2024 29, order dated 12/10/2024 30, and judgment 31 to Patent Trademark Office, Alexandria VA.