2025-cv-00415

COMPLAINT filed by Dyson Technology Limited; Filing fee $ 405, receipt number AILNDC-22951214.

Exhibit 2

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 1 - Parts 1-2 regarding complaint[1]

MOTION by Plaintiff Dyson Technology Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dyson Technology Limited

Notice of Claims involving Patents by Dyson Technology Limited

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Lawrence J. Crain

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiff Dyson Technology Limited by Andrew Daniel Burnham

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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

BOND in the amount of $5,000.00 Check, Receipt 100015775 posted by Dyson Technology Limited (qrtr,)

NEW PARTIES: Good Friiends, Hey WhiteLeaf, Yajing Tech, RAISBAG INC and 101683748 added to case caption.

MAILED patent report to Patent Trademark Office, Alexandria VA

AMENDED complaint by Dyson Technology Limited against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 2

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Amended Schedule A regarding amended complaint[13]

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 1 - Part 1 regarding amended complaint[13]

MOTION by Plaintiff Dyson Technology Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Dyson Technology Limited in support of motion for temporary restraining order[16]

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

DECLARATION of Giles Samuel Lane regarding memorandum in support of motion[17]

Exhibit 1

SEALED EXHIBIT by Plaintiff Dyson Technology Limited Exhibit 2 - Part 1 regarding declaration[19]

MOTION by Plaintiff Dyson Technology Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Dyson Technology Limited in support of motion for miscellaneous relief 21

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order[16], motion for miscellaneous relief[21], motion for leave to file[4] before Honorable LaShonda A. Hunt on 1/22/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to file under seal [4] is granted. Schedule A [2], Exhibit 1 to the Complaint [3], and Exhibit 2 to the Declaration of Giles Samuel Lane [20] shall remain sealed until further court order. No appearance is necessary on 1/22/25. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery [16] and Motion for Electronic Service of Process [21] are granted. 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. The Court finds that (1) the submitted evidence establishes a likelihood of success on the merits (including evidence of active infringement and sales into Illinois); (2) the harm to plaintiff is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with Plaintiff's ability to control its intellectual property; and (4) 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 way to communicate with these online marketplace defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the Court will revisit the asset freeze, joinder, and personal jurisdiction. A $5,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. No appearance is necessary on 1/22/25. Mailed notice (gel,)

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable LaShonda A. Hunt on 1/17/2025. Mailed notice (gel,)

Registry Deposit Information Form by Dyson Technology Limited

MOTION by Plaintiff Dyson Technology Limited for extension of time of Temporary Restraining Order

MEMORANDUM by Dyson Technology Limited in support of extension of time[29]

DECLARATION of Justin T. Joseph regarding memorandum in support of motion[30]

NOTICE of Motion by Justin Tyler Joseph for presentment of extension of time[29] before Honorable LaShonda A. Hunt on 1/30/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's ex parte motion to extend the temporary restraining order [29] is granted. The TRO is extended to 2/14/25 for the reasons stated in the order granting the initial TRO [26], [27]. Motion hearing set for 1/30/25 is stricken. Mailed notice (gel,)

MOTION by Plaintiff Dyson Technology Limited for preliminary injunction

Exhibit A

MEMORANDUM by Dyson Technology Limited in support of motion for preliminary injunction[34]

DECLARATION of Justin T. Joseph regarding memorandum in support of motion[35]

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction[34] before Honorable LaShonda A. Hunt on 2/13/2025 at 10:00 AM.

Exhibit A

SUMMONS Returned Executed by Dyson Technology Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/10/2025, answer due 3/3/2025.

Declaration of Andrew D. Burnham

Exhibit A

MINUTE entry before the Honorable LaShonda A. Hunt: Hearing on Plaintiff's motion for preliminary injunction 34 is reset from in-person on 2/13/25 to telephonic on 3/4/25, at 9:45AM. Attorneys/parties may appear by dialing: 1-650-479-3207 and entering access code: 2311 499 1046. No attendee code is required. Please review in advance the policies governing telephonic hearings that can be found on Judge Hunt's webpage on the court website. The motion may be considered unopposed as to any Defendant who does not file an objection by 3/3/25 and/or appear at the motion hearing. For the reasons stated in the Court's initial order entering the TRO, the TRO is extended to and including the date the Court adjudicates the motion for preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed. R. Civ. P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Plaintiff must serve a copy of this minute order upon all affected Defendants within one business day of its entry on the docket and promptly file proof of that service. Mailed notice (gel,)

CERTIFICATE of Service by Plaintiff Dyson Technology Limited regarding terminate deadlines, set motion and R&R deadlines/hearings, 39

(Exhibit A)

MINUTE entry before the Honorable LaShonda A. Hunt: Telephonic motion hearing held. For the reasons stated on the record, Plaintiff's unopposed motion for preliminary injunction [34] is granted. Enter Preliminary Injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Amended Schedule A [14] are added to the court's docket within five business days. The Clerk is requested to unseal any previously sealed documents. By 3/21/25, Plaintiff is ordered to file any motions for entry of default pursuant to Federal Rule of Civil Procedure 55(a). If there are any remaining defendants against whom default and default judgment are not being sought, Plaintiff is ordered to file by the same date a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. Mailed notice (gel,)

PRELIMINARY INJUNCTION ORDER Signed by the Honorable LaShonda A. Hunt on 3/4/2025. Mailed notice (gel,)

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to certain defendant

MINUTE entry before the Honorable LaShonda A. Hunt: Based on Plaintiff's notice of dismissal [43], this case is dismissed as to Defendant No. 3 Yajing Tech only. Mailed notice (gel,)

ATTORNEY Appearance for Defendants Good Friiends, Hey WhiteLeaf by Hua Chen

MOTION by Defendants Good Friiends, Hey WhiteLeaf for extension of time to file answer regarding amended complaint[13] UNOPPOSED

NOTICE of Motion by Hua Chen for presentment of motion for extension of time to file answer[46] before Honorable LaShonda A. Hunt on 4/2/2025 at 10:00 AM.

NOTICE of Voluntary Dismissal by Dyson Technology Limited as to Certain Defendants

STATUS Report Pursuant to [41] by Dyson Technology Limited

Exhibit A

MINUTE entry before the Honorable LaShonda A. Hunt: Defendants Good Friiends' and Hey WhiteLeaf's unopposed motion for extension of time 46 is granted. Good Friiends' and Hey WhiteLeaf's response(s) to the amended complaint 13 are due by 4/11/25. The motion hearing set for 4/2/25 47 is stricken. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil Procedure 41(a)(1) and the Plaintiff's Notice of Dismissal 48, this action is being dismissed as to Defendants RAISBAG INC and 101683748 only. Mailed notice (gel,)

ANSWER to amended complaint by Good Friiends, Hey WhiteLeaf

MINUTE entry before the Honorable LaShonda A. Hunt: With the filings of an answer by the only remaining Defendants Good Friiends and Hey WhiteLeaf 52, the pleadings are finalized. Accordingly, by 4/25/25, the parties must meet and confer and file a Joint Initial Status Report for New Case. A template for the report can be found on Judge Hunt's webpage under "Initial Status Conference and Status Report." The Court will enter an appropriate order after reviewing the report. Mailed notice (gel,)

STATUS Report Pursuant to [53] (Joint) by Dyson Technology Limited

MINUTE entry before the Honorable LaShonda A. Hunt: The parties' joint status report 54 indicates that they have reached a settlement and anticipate resolution within 14 days. Accordingly, the parties are ordered to file a stipulation of dismissal by 5/9/25. Otherwise, the case will be dismissed without prejudice with leave to reinstate within 60 days, at which point the dismissal will automatically convert to one with prejudice without further order of the court. Mailed notice.

STIPULATION of Dismissal as to Defendants Good Friiends (Def. No. 1) and Hey WhiteLeaf (Def. No. 2)

MINUTE entry before the Honorable LaShonda A. Hunt: Pursuant to Federal Rule of Civil procedure 41(a)(1) and the parties' Stipulation of Dismissal [56], this case is being dismissed with prejudice as to the two remaining Defendants Good Friiends (Def. No. 1) and Hey WhiteLeaf (Def. No. 2). All pending motions and deadlines are terminated as moot. Civil case terminated. Mailed notice (gel,)

ENTERED JUDGMENT Mailed notice(gel,)

MAILED Patent report with certified copy of minute order dated 5/9/2025 to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Dyson Technology Limited for Release of Bond

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for miscellaneous relief[60] before Honorable LaShonda A. Hunt on 8/26/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for release of bond [60] is granted. Enter Order. The motion hearing set for 8/26/25 [61] is stricken. Mailed notice (gel,)

ORDER TO RELEASE BOND TO PLAINTIFF Signed by the Honorable LaShonda A. Hunt on 8/21/2025. Mailed notice (gel,)