2025-cv-00193

COMPLAINT filed by Bounce Curl, LLC; Filing fee $ 405, receipt number AILNDC-22924800.

Exhibit 2

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

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

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

CIVIL Cover Sheet

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

Notice of Claims Involving Patents by Bounce Curl, LLC

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

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

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

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

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 John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 1).

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

NEW PARTIES: 0000MAD, A22JK4H9EW3MS7, A2PHWCK0P88L59, A392RQAFDS2NEX, A3S0JRLO0SHT2J, baotian store, CaiMiaO, Cissy's Choice, CityonCloud, CongCJKK, CZG Hair, DATONGCHAOSHENDIZISHANGWUZHONGXING, Ecosheek, enjoylifes, Fung Ai Electronics, hangzhoulanyuemaoyiyouxiangongsi, HeQiuU, HuaJianMaoYiShangMaoYouXianGongSi, Inkeeshen, jianjiajia, Keqinghua, LANKUDANG, LexeMon, LIUYAN123, Ming Sen Shang Mao, New Dongyuan protective film materials Technology, oild637, Poxted, Punki, shaojunli, Shuangxuan, Shulgf, siyibaiqian, snwangshengneng, Sonnorel, sorneic, VOCO Jewelry Store88, XieHaiWen11, yamitu, yangqunfushi, YANHONGJINCHUKOU, YaoHuiI, YHL sup, YUEYUEKJING, ZangFeiFeiUS, Zhangjunhua, Zhangqiaoqiao, ZHENCAIBAIHUO, zzhab, AskStar, dashfreedom88, good-faming, guangzhouyinfeisha-0, gulopp_sre, knhmsh212, np-oppoer, yuplmer, Efforest, FunnyElec, BaoHuiYun, foshanshiqiushigashangmao, GeSHOP, GUANTONG1, kft mall, lixiao, MaoMao1 and youmaiwangl added to case caption.

NEW PARTIES: Guangzhou Shangye Health Technology Co., Ltd, Baojuze Auto Parts, nexincr, urbangue, vixqyv, xyazsk and Lanzon added to case caption.

Terminating Lanzon, nexincr, urbangue, vixqyv, xyazsk, Baojuze Auto Parts and Guangzhou Shangye Health Technology Co., Ltd

MAILED original sixty seven-thousand-dollar ($67,000) surety bond posted by Bounce Curl, LLC to Greer, Burns & Crain 200 W. Madison Street Suite 2100 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7785 74.

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [12], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 1, 7, 58, 60, 61, 62, and 71 are dismissed from this case. Mailed notice

MAILED Patent report to Patent Trademark Office, Alexandria VA

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion to seal [4] is granted. Exhibit 1 to the Complaint [2] and Schedule A to the Complaint [3], filed provisionally under seal, are permitted to remain under seal. In addition, by 1/23/2025, the plaintiff is directed to file a memorandum explaining why joinder is proper under the America Invents Act, 35 U.S.C. § 299, particularly given that not all defendants seem to sell the same product. See, e.g., Oakley, Inc. v. Schedule A, No. 21-cv-00536, 2021 WL 308882, at *1-2 (N.D. Ill. Jan. 30, 2021) (propriety of joinder tied to sale of same accused product, and allegation "that the defendants all sold infringing products" insufficient). Mailed notice

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

MEMORANDUM by Bounce Curl, LLC in support of motion for temporary restraining order[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

DECLARATION of Merian Odesho regarding memorandum in support of motion[17]

Exhibit 1

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 2 - Parts 1-2 regarding declaration[19]

SUPPLEMENT to motion for temporary restraining order[16]

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

MEMORANDUM by Bounce Curl, LLC in support of motion for miscellaneous relief[22]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[23]

MEMORANDUM by Bounce Curl, LLC Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum[25]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for a temporary restraining order [16] is granted. Enter temporary restraining order. The plaintiff's motion for electronic service of process [22] is also granted. Finally, on review of the plaintiff's memorandum [25] and supporting evidence, the Court finds that the plaintiff has set forth sufficient allegations and evidence to establish that joinder is proper under the America Invents Act, 35 U.S.C. § 299. Specifically, the plaintiff has shown that the defendants' alleged infringement is part of the same "series of transactions or occurrences" and that they are selling "the same accused product or process" as required by § 299(a)(1). Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 1/22/2025. Mailed notice

Registry Deposit Information Form by Bounce Curl, LLC

SURETY BOND in the amount of $ 67,000 posted by Bounce Curl, LLC. (Document not imaged)

MOTION by Plaintiff Bounce Curl, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Bounce Curl, LLC in support of motion for preliminary injunction[31]

Declaration of Andrew D. Burnham

SUMMONS Returned Executed by Bounce Curl, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/31/2025, answer due 2/21/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 31 is taken under advisement. Any objection or response is due before 2/5/25. Upon review of the certificate of service, the Court directs the plaintiff, by 2/4/2025, 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 2/5/2025. 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 Bounce Curl, LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 34

Exhibit A

(Exhibit B)

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 [31] 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 2/11/2025 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 Bounce Curl, LLC 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. 41 is dismissed from this case. Mailed notice

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

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 nos. 34, 45, 64, 69, and 72 are dismissed from this case. Mailed notice

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

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

Exhibit A

MEMORANDUM by Bounce Curl, LLC in support of motion for entry of default, motion for default judgment[43]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [42], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 11, 28, 52, and 73 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [43] is taken under advisement. Any objections or responses are due by 3/10/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 3/3/2025. 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 Bounce Curl, LLC 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

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal [49], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 13, 30, 38, and 70 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff is directed to submit, in Word format, a revised proposed default judgment order that reflects all recent defendant dismissals. The plaintiff should send the proposed order to Proposed_Order_Tharp@ilnd.uscourts.gov. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [43] is granted. Enter default judgment order. Civil case terminated Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 3/12/2025. Mailed notice

MAILED patent report with order dated 3/12/2025 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order[53] in the amount of THE JUDGMENT AMOUNT as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [55], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant nos. 24 and 53. Mailed notice

FULL SATISFACTION of Judgment regarding order[53] in the amount of THE JUDGMENT AMOUNT as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 57, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 18. Mailed notice

FULL SATISFACTION of Judgment regarding order[53] in the amount of THE JUDGMENT AMOUNT as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [59], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant No. 37. Mailed notice