2025-cv-00063

COMPLAINT filed by Leatherman Tool Group, Inc.; Filing fee $ 405, receipt number AILNDC-22908391.

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Leatherman Tool Group, Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Leatherman Tool Group, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Leatherman Tool Group, Inc.

Notice of Claims Involving Trademarks by Leatherman Tool Group, Inc.

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Yu Hin Jeffrey Tsai (Tsai, Yu Hin)

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

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

NEW PARTIES: Jiangsu Yabang Outdoor Products Co., Ltd., Shenzhen Qindao Network Technology Co., Ltd., Shijiazhuang Gaiying Technology Co., Ltd., A16YFYFJNDT03C, A2QAAEIN5L9SPX, A76FGEAFAIH1K, anubisi shop, badianbadianzi, Bianbian USA xiaodian, BINLUSH, Bo6755, Building 9, chenhaimingxiaodian, chixiangyidianshangyouxiangongsi, chuanssm, CuiTby, dongdashandianzishangwu, feirendianzishangwu, GMBstore, HeYaA, HuaiBaoMh, IndusPro Mart, JingXianMao, JINYUNJIUZHUANG, JiShEnG, KaiLAImei, meijiadianshang, minrui0shop, Myulei&Xhuijie, nankai1012, OHZOIRIC, pamierdianzishangwu, shuangjiadianzishangwu, TaoMeNg, tianzhenanyiningshangmaoyouxiangongsi, TingHua, Tongxiangtrade, wangwangxixi, wuhuxiefeiliandianzishangwu, wuhuximalayadianzishangwuyouxiangongsi, wumingdadaos, Xiaoyu USA branch, xinyexianxingaishangmaoyouxiangongsi, XUJINJIN, yiganqingdianzishangwu, yunhaizhaoshangmao, zdl520, zhanghaiyanWQ, zhengzhouangyushangmaoyouxiangongsi, ZHIYIYI, Zong&Bear store US, ZunBaA, happylife9139, optilink shop, oushuo, Kangqunbaozhuang, ONCES-US, Rzmy direct, SJWsp and Yilongtongdashangwultdshopx added to case caption.

MAILED Original sixty-thousand-dollars ($60,000) surety bond posted by Leatherman Tool Group to Amy Crout, Ziegler Greer, Burns & Crain Ltd. 200 W Madison St, Ste 2100 Chicago, IL 60606 certified mail # 9589 0710 5270 0579 7829 39

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff's motion for leave to file under seal [3] is granted. Schedule A to the Complaint [2], provisionally filed under seal, may remain under seal. Mailed notice

MOTION by Plaintiff Leatherman Tool Group, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for temporary restraining order[14]

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

DECLARATION of Doug Anderson regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Leatherman Tool Group, Inc. Exhibit 2 - Part 1 regarding declaration[17]

MOTION by Plaintiff Leatherman Tool Group, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for miscellaneous relief[19]

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

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff's motion for a temporary restraining order 14 denied without prejudice. While the complaint 1, TRO memorandum 15, and proposed TRO reference 26 different trademarks, the screenshots in Exhibit 2 to the Declaration of Doug Anderson only demonstrate infringement of one. Plaint may submit a renewed motion (and, if needed, an amended complaint) that addresses or moots these issues by 1/22/2025. If the renewed motion contains new or different screenshots, it must be accompanied by: (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case, (3) a certification that the plaintiff has not used any of the screenshot evidence supplied in support or its motion in any prior proceeding, and (4) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademark[s] each defendant has allegedly infringed. The plaintiff's motion for electronic service of process 19 is granted. Mailed notice

MOTION by Plaintiff Leatherman Tool Group, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery (Renewed)

SUPPLEMENT to motion for temporary restraining order[23] per [22]

SEALED EXHIBIT by Plaintiff Leatherman Tool Group, Inc. Exhibit 1 regarding supplement[24]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's renewed ex parte motion for TRO [23] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Orde. Signed by the Honorable John J. Tharp, Jr on 1/16/2025:Mailed notice

Registry Deposit Information Form by Leatherman Tool Group, Inc.

SURETY BOND in the amount of $ 60,000.00 posted by Leatherman Tool Group, Inc.

MOTION by Plaintiff Leatherman Tool Group, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for preliminary injunction[29]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[30]

SUMMONS Returned Executed by Leatherman Tool Group, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/27/2025, answer due 2/17/2025.

Declaration of Y. Jeffrey Tsai

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [29] is taken under advisement. Any objection or response is due before 2/4/2025. Upon review of the declaration of service, the Court directs the plaintiff, by 1/30/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 2/4/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Leatherman Tool Group, Inc. regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 33

(Exhibit A)

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [29] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 2/11/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 2/6/2025. Mailed notice

NOTICE of Voluntary Dismissal by Leatherman Tool Group, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 38, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 22 is dismissed from this case Mailed notice

NOTICE of Voluntary Dismissal by Leatherman Tool Group, Inc. as to a certain Defendant

MOTION by Plaintiff Leatherman Tool Group, Inc. for entry of default, MOTION by Plaintiff Leatherman Tool Group, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for entry of default, motion for default judgment[41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 40, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 50 is dismissed from this case. Mailed notice

DUPLICATE ENTRY REMOVED (Additional attachment(s) added on 2/21/2025: # 1 Duplicate Entry).

NOTICE of Correction.

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 41 is taken under advisement. Any objections or responses are due by 3/3/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 2/24/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this Order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Leatherman Tool Group, Inc. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 47

Exhibit A

(Exhibit B)(Tsai, Yu Hin)

ATTORNEY Appearance for Defendant Rzmy direct by Christopher Paul Keleher

NOTICE of Voluntary Dismissal by Leatherman Tool Group, Inc. as to certain defendant

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Madeline Halgren

NOTICE of Voluntary Dismissal by Leatherman Tool Group, Inc. as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [50], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 15 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [52], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 58 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [50] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 3/4/2025. Mailed notice

EMAILED Trademark report with certified copy of minute order dated 3/4/25 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order, terminated case[56] in the amount of $25,000 as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 58, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 17, 18, 31, 32, 39, and 40. Mailed notice

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7829 39