2024-cv-12353

COMPLAINT filed by Ronald Kuang; Filing fee $ 405, receipt number AILNDC-22785504.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Ronald Kuang Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Ronald Kuang by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Ronald Kuang by Adam Grodman

ATTORNEY Appearance for Plaintiff Ronald Kuang by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Ronald Kuang by Christopher Romero

ATTORNEY Appearance for Plaintiff Ronald Kuang by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Ronald Kuang by Yanling Jiang

ATTORNEY Appearance for Plaintiff Ronald Kuang by Yi Bu

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 3).

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 Ronald Kuang for leave to file under seal

MOTION by Plaintiff Ronald Kuang for leave to file excess pages

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion to seal 12 is granted provisionally and for now, given the asset-restraint goal. The motion for extra pages 13 is granted. On review of the motion for TRO and other relief 14, the Plaintiff shall file a supplement to the motion, on or before 12/16/2024, explaining why the six defendants on Amended Schedule A, R. 11, are properly joined under Estee Lauder Cosmetics Ltd. v. Schedule A, Case No. 19-cv-7878, 2020 WL 433870 (N.D. Ill. Jan. 27, 2020). The supplement may be filed under seal given the need to refer to the content of the online sites. The motion hearing is vacated. To track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 12/20/2024 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MEMORANDUM Establishing that Joinder is Proper

(Exhibit 1)

MINUTE entry before the Honorable Edmond E. Chang: The joinder issue is under advisement. The tracking status hearing of 12/20/2024 is reset to 01/31/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

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.

MAILED copyright report to Registrar, Washington DC.

(Copyrights)

MINUTE entry before the Honorable Edmond E. Chang: The joinder issue remains under advisement. The tracking status hearing of 01/31/2025 is reset to 02/28/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder issue, see R. 19, remains under advisement. The tracking status hearing of 02/28/2025 is reset to 03/28/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, see R. 19, remains under consideration. The tracking status hearing of 03/28/2025 is reset to 04/18/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, see R. 19, remains under advisement, so the tracking status hearing of 04/18/2025 is reset to 05/09/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The joinder filing, see R. 19, remains under advisement. The tracking status hearing of 05/09/2025 is reset to 06/13/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: (1.) On review of the joinder filing, R. 19, given the unique similarities amongst each of the six Defendants, joinder is proper (at least absent adversarial presentation). Although the advertising text is not starkly unique in that the text uses common words and the sequence of words is not particularly unique, the 17-word text is exactly the same. On top of that, all six product listings appeared on the same exact date and use the same (false) brand name. (2.) In this copyright-infringement case, the Plaintiff's motion [14] for temporary restraining order and other relief is granted. An order will be entered under seal separately and will become effective when posted on the docket (which means that the 14-day clock does not start to run until posted). Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. � 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. �504(b). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendants, who likely would seek to transfer the money elsewhere. The Plaintiff's request for electronic service of process is granted. The Plaintiff's TRO extension motion, if appropriate, is due by 10/07/2025, and a status report is due on that date as well. The tracking status hearing of 10/10/2025 remains in place. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/29/2025. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/29/2025. Emailed notice

MOTION by Plaintiff Ronald Kuang for preliminary injunction

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction [38] is granted. Given the response deadline of 10/27/2025, R. 41, the tracking status hearing of 10/10/2025 is reset to 11/07/2025 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 10/31/2025. If the Defendants do not answer on time, then they shall be deemed to be in default as of 10/28/2025, and the Plaintiff shall file the motion for default judgment in a sum certain by 10/31/2025. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 10/08/2025. Emailed notice