2024-cv-11392

2024-cv-11392 Bounce Curl, LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :11/5/2024
BrandEdgeLift 梳子
Court :Northen District of Illinois
Law FirmGBC

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Date

Document

1

Nov. 5, 2024

COMPLAINT filed by Bounce Curl, LLC; Filing fee $ 405, receipt number AILNDC-22692025.

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

2

Nov. 5, 2024

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Schedule A regarding complaint[1]

Nov. 5, 2024

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

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

NEW PARTIES: A1ULYOK0FDX1NB, A23N0PUA3VCGDC, A31B33SF2B96E4, A32DXKR0MCSX2P, A3P3RCNW73MD49, AEUZ1V2JA2YYW, aijimikj, AIRuiKA, Annser direct, AROZ9RGCTRLMH, atootec, AUO111NE33928, Azooken Online, basior, Bestone Jewelry, bichuangliwei, binglang, Bobobag, CBNRLOPOP-US, ChenCheng store US, chengdujuhaihengshengkejiyouxiangongsi, CMC' Shop, ColayeristDirect, CXB Preferred, dingdangding, ElegGlo, ETRGASG, fengjiacenyin, fengmingz, FGRGIKI, FVAQL, GaoZhuUS, gongyunfeng123, GUANJIN, GuiYangG, Haibrush, haikoujuyixuanbaihuoshanghang, HAI-QING, HALEYLIN, Hao Zhu, haopinfuzhuang, hongMaiZhiHuiWenHuaChuanMei, HuiQuan, JIANJUN Store, JianT, JIAYU STOR, jibangxing, JSOUSWUT-US, Ke lly, kuangbiaobaihuo, KVV STORE, lailaiyueke, LANMFU, Large bottled water, LINTON.STORE, LiPengpengbeimei, LIUCHAOKUAILE, Liuhongguojiwuliu, lvguangshangwu, Maxiayuanshangmaos, Mingsuan, MinXiaBH, Nagobi, nanjingsuyagoushangmaoyouxiangongsi, nanjingzhizhishenshangmaoyouxiangongsi, OBIWEX, OERYIEG, OTO BELLA, PeiXianChunXunShangMaoYouXianGongSi, Qingyu Teil, qixixiaodian, QiYueZhenXuan, R&F Beauty, RenXianXianShangMao, RSHUYIN, Rybbhdzz, Rydox tech Boutique US, shaoyuntengwangpu, SHESABLE, SMARTBEST-US, STengDa, Su Soft towel Star, suhh, suniya1, time to live, TOMEGAVT, Tongling Xiaoxiangguo, txldd and uhovho-Direct added to case caption.

3

Nov. 5, 2024

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 1 - Parts 1-2 regarding complaint[1]

4

Nov. 5, 2024

MOTION by Plaintiff Bounce Curl, LLC for leave to file under seal

5

Nov. 5, 2024

CIVIL Cover Sheet

6

Nov. 5, 2024

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. Bounce Curl, LLC is directed to file the Civil Cover Sheet within 14 days of this notification. Signed by the Executive Committee.

7

Nov. 5, 2024

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bounce Curl, LLC

8

Nov. 5, 2024

Notice of Claims Involving Patents by Bounce Curl, LLC

9

Nov. 5, 2024

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Justin R. Gaudio

10

Nov. 5, 2024

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Amy Crout Ziegler

11

Nov. 5, 2024

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Justin Tyler Joseph

12

Nov. 5, 2024

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Jennifer Van Nacht

13

Nov. 6, 2024

MAILED Patent report to Patent Trademark Office, Alexandria VA.

14

Nov. 7, 2024

MOTION by Plaintiff Bounce Curl, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

15

Nov. 7, 2024

MEMORANDUM by Bounce Curl, LLC in support of motion for temporary restraining order[14]

16

Nov. 7, 2024

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

17

Nov. 7, 2024

DECLARATION of Merian Odesho regarding memorandum in support of motion[15]

Exhibit 1

18

Nov. 7, 2024

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 2 - Parts 1-2 regarding declaration[17]

19

Nov. 7, 2024

MOTION by Plaintiff Bounce Curl, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

20

Nov. 7, 2024

MEMORANDUM by Bounce Curl, LLC in support of motion for miscellaneous relief[19]

21

Nov. 7, 2024

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

22

Nov. 7, 2024

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[19], motion for leave to file[4], motion for temporary restraining order[14] before Honorable Jorge L. Alonso on 11/13/2024 at 09:30 AM.

23

Nov. 12, 2024

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 4 14 19 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 $90,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 11/13/24 is stricken. Notice mailed by Judge's staff

24

Nov. 12, 2024

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 11/12/2024. Notice mailed by Judge's staff

25

Nov. 12, 2024

Registry Deposit Information Form by Bounce Curl, LLC

26

Nov. 18, 2024

INJUNCTION BOND in the amount of $ 90,000.00 posted by Bounce Curl, LLC (Document not scanned).

27

Nov. 21, 2024

MOTION by Plaintiff Bounce Curl, LLC for preliminary injunction

(Exhibit A)

28

Nov. 21, 2024

MEMORANDUM by Bounce Curl, LLC in support of motion for preliminary injunction 27

Declaration of Justin T. Joseph

(Exhibit 1)

29

Nov. 21, 2024

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 27 before Honorable Jorge L. Alonso on 11/26/2024 at 09:30 AM.

(Exhibit A)

30

Nov. 21, 2024

SUMMONS Returned Executed by Bounce Curl, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/21/2024, answer due 12/12/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

31

Nov. 25, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to a certain Defendant

32

Nov. 25, 2024

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 11/26/24 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

33

Nov. 26, 2024

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [27] 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. Telephonic status hearing set for 1/14/25 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

34

Nov. 26, 2024

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 11/26/2024. Notice mailed by Judge's staff

35

Dec. 3, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to certain Defendants

36

Dec. 5, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to certain Defendants

37

Dec. 12, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to certain defendant

38

Dec. 13, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to a certain Defendant

39

Dec. 16, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to a certain Defendant

40

Dec. 16, 2024

MOTION by Plaintiff Bounce Curl, LLC for entry of default, MOTION by Plaintiff Bounce Curl, LLC for default judgment as to all Defendants with the exception of certain Defendants

Exhibit A

41

Dec. 16, 2024

MEMORANDUM by Bounce Curl, LLC in support of motion for entry of default, motion for default judgment, [40]

Exhibit 1

42

Dec. 16, 2024

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[41]

Exhibit 1

43

Dec. 16, 2024

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment, [40] before Honorable Jorge L. Alonso on 12/19/2024 at 09:30 AM.

Exhibit A

44

Dec. 18, 2024

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 12/19/24 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

45

Dec. 19, 2024

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Andrew Daniel Burnham

46

Dec. 19, 2024

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of Defendant Nos. 41, 46, 51, 53 and 60 40 is granted. Enter Default Judgment Order. Telephonic status hearing previously set for 1/14/25 is stricken and reset to 1/22/25 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

47

Dec. 19, 2024

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 12/19/2024. Notice mailed by Judge's staff

49

Dec. 20, 2024

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/20/2024: Mailed notice.

48

Dec. 27, 2024

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to certain defendants

50

Jan. 16, 2025

FULL SATISFACTION of Judgment regarding order 47 in the amount of THE JUDGMENT AMOUNT as to certain defendants

51

Jan. 21, 2025

MINUTE entry before the Honorable Jorge L. Alonso: In light of the notice of voluntary dismissal, this case is dismissed. Status hearing previously set for 1/22/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

52

Jan. 22, 2025

EMAILED Patent report with certified copy of minute order dated 1/21/25 to Patent Trademark Office, Alexandria VA

53

July 10, 2025

FULL SATISFACTION of Judgment regarding order 47 in the amount of THE JUDGMENT AMOUNT as to certain defendant

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