2024-cv-12600

COMPLAINT for Copyright Infringement filed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD; Jury Demand. Filing fee $ 405, receipt number AILNDC-22812849.

Exhibit 1 to the Complaint

(Exhibit 2 to the Complaint)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Shawn Anthony Mangano

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Gokalp Bayramoglu

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.

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 3).

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto

NEW PARTIES: AIC Apparel, bestbusy, cookieimage5ci, downlightdirect, Dromiyafashion, earlykoo18rk, earnjc17rk, esterwind30rk, edjwendd, ezjwemczeal, FahionShop, fikinterkite, Find charming, frdroadd, frirising, hcnonet2nn, ininttkx, ireczoulkx, isastaykx, Kcon Apparel, safenoon, samess07rk, sunshingshoppe, tuoyou8-64 shop, Unique-JC-jewelry and Wholesale*Clothing*Shop aka angelcity_shop added to case caption.

Terminating Wholesale*Clothing*Shop aka angelcity_shop and tuoyou8-64 shop

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD for leave to file excess pages for Plaintiff's Motion for Temporary Restraining Order

MAILED copyright report to Registrar, Washington DC.

Copyrights

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION

Declaration of Katherine M. Kuhn ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Exhibit 6 to the Declaration of K. Kuhn

Exhibit 7 to the Declaration of K. Kuhn

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for leave to file excess pages[9], motion for temporary restraining order, [11] before Honorable Sara L. Ellis on 12/19/2024 at 01:45 PM.

MINUTE entry before the Honorable Sara L. Ellis: Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for leave to file excess pages [9] and denies Plaintiff's motion for a temporary restraining order [11] without prejudice. Plaintiff filed this case against 43 defendants for infringing three copyrights registered to Plaintiff, with one of the copyrights covering 750 photographs. Under Rule 20, a plaintiff may join multiple defendants in a single action if: (1) the claims against them are asserted with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) a question of law or fact common to all defendants exists. Fed. R. Civ. P. 20(a)(2)(A)(B). In reviewing the materials filed by Plaintiff in this case, it does not appear that joinder is proper as to all Defendants. As the Court stated in Roadget Business Pte. Ltd. v. The Individuals, Corporations, Limited Liability Cos., Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, alleging that multiple defendants have infringed on the same copyright, trademark, or patent in the same way, without more, does not create the substantial evidentiary overlap required to find joinder proper. No. 23 C 17036, 2024 WL 1858592, at *67 (N.D. Ill. Apr. 29, 2024). The Court directs Plaintiff to file an amended complaint by 1/6/2025, as well as a statement on joinder explaining how the remaining Defendants comply with the Courts order in Roadget. The Court sets a status hearing set for 1/21/2025 at 9:30 AM. Mailed 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.

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto for Copyright Infringement

Exhibit 1 to the First Amended Complaint

Exhibit 2 to the First Amended Complaint

SUPPLEMENT to amended complaint, [16] Supplemental Brief in Compliance with Docket 14

Declaration of Katherine M. Kuhn ISO Supplemental Brief

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Joseph W. Droter ISO Supplemental Brief

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order Amended Motion for Temporary Restraining Order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION

Declaration of Katherine M. Kuhn ISO Amended Motion for Temporary Restraining Or

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Exhibit 6 to the Declaration of K. Kuhn

Exhibit 7 to the Declaration of K. Kuhn

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's amended motion for entry of a temporary restraining order [18]. The Court strikes the status date set for 1/21/2025 and resets it to 2/4/2025 at 9:45 AM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Sara L. Ellis on 1/17/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto on 1/27/2025, answer due 2/17/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION

Declaration OF KATHERINE M. KUHN IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY

Declaration OF LIANGJIE LI IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION

NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for preliminary injunction, [23] before Honorable Sara L. Ellis on 2/4/2025 at 09:45 AM.

SURETY BOND in the amount of $ 26,000 posted by Hong Kong Leyuzhen Technology Co. Limited. (Document not scanned)

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for leave to deposit finds into the Court registry [21]. The Court orders Plaintiff to deposit the bond amount of $26,000 USD with the Court's registry. The Court grants Plaintiff's motion for preliminary injunction [23]. The Court strikes the status date set for 2/4/2025 and resets it to 3/6/2025 at 1:45 PM. Plaintiff should file any motion for entry of default and for default judgment and notice the motion for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice

ORDER FOR PRELIMINARY INJUNCTION. Signed by the Honorable Sara L. Ellis on 2/5/2025:Emailed notice

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendant 26

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendant 24

MINUTE entry before the Honorable Sara L. Ellis: The Court strikes the status date set for 3/6/2025 and resets it to 3/13/2025 at 1:45 PM. Plaintiff should file any motion for entry of default and for default judgment and notice the motion for presentment at the next status date. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Emailed notice. (jn,)

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 24 Defendants Identified on Schedule A

Exhibit Memorandum of Law in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn ISO Motion for Default and Default Judgment

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Declaration of Lianjie Li in Support of Default and Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [31] before Honorable Sara L. Ellis on 3/18/2025 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: Telephone conference hearing held and continued to 3/18/25 at 1:30 pm. Bayramoglu Law Offices LLC 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf.https://www.ilnd.uscourts.gov/Videos.aspx? folder=_cmecf&play=Add_Terminate.mp4. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting 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. Mailed notice

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for entry of default and default judgment [31]. The Court enters judgment in favor of Plaintiff and against Defendants identified in Amended Schedule A. Case terminated. Emailed notice

FULL SATISFACTION of Judgment regarding order on motion for default judgment, terminate deadlines and hearings, [33] ONLY as to Defendants 3, 4, 6, 7, 9, 12, 13, 14, 15, 16, 18, 19, 21 and 22

FINAL DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 4/2/2025. Emailed notice