2025-cv-00589

COMPLAINT filed by Fear of God, LLC; Filing fee $ 405, receipt number AILNDC-22967649.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Fear of God, LLC Schedule A regarding complaint 1

MOTION by Plaintiff Fear of God, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Fear of God, LLC

Notice of Claims Involving Trademarks by Fear of God, LLC

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Yu Hin Jeffrey Tsai (Tsai, Yu Hin)

CASE ASSIGNED to the Honorable Jeffrey I Cummings. 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: anchengxiangsunyibomaoyiyouxia, Chengchen, zelingfengmaoyi, keyouhushangmao and youpinchuangkuaaa added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Fear of God, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Fear of God, LLC Amended Schedule A regarding amended complaint 13

MOTION by Plaintiff Fear of God, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Fear of God, LLC in support of motion for temporary restraining order 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

DECLARATION of Glenn Milus regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff Fear of God, LLC Exhibit 3 - Part 1 regarding declaration 18

(Exhibit 3-1)

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

MEMORANDUM by Fear of God, LLC in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal 3, ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 15, and motion for electronic service of process 20 are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and 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 effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 3/10/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 1/29/2025. Mailed notice

DECLARATION of Justin R. Gaudio

MOTION by Plaintiff Fear of God, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Fear of God, LLC in support of motion for preliminary injunction 26

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 27

SUMMONS Returned Executed by Fear of God, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/7/2025, answer due 2/28/2025.

Declaration of Y. Jeffrey Tsai

(Exhibit A)(Tsai, Yu Hin)

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 26. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before February 20, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's order entering the TRO, the TRO is extended to and including the date upon which the Court adjudicates the motion for a 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. Mailed notice

CERTIFICATE of Service by Plaintiff Fear of God, LLC regarding text entry, 30

(Exhibit A)(Tsai, Yu Hin)

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Hannah Alexa Abes

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction [26] is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. If plaintiff intends to move for an order of default and default judgment, plaintiff shall file its motion on or before 3/28/25. The 3/10/25 tracking status hearing is stricken and re-set to 4/18/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

PRELIMINARY INJUNCTION Order Signed by the Honorable Jeffrey I Cummings on 3/3/2025. Mailed notice

MOTION by Plaintiff Fear of God, LLC for entry of default, MOTION by Plaintiff Fear of God, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Fear of God, LLC in support of motion for entry of default, motion for default judgment[35]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[36]

Exhibit 1

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 37 for entry of default and default judgment against defendant. The remaining defendants has failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 3/19/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice

CERTIFICATE of Service by Plaintiff Fear of God, LLC regarding text entry, 38

(Exhibit A)

ATTORNEY Appearance for Plaintiff Fear of God, LLC by Luana Faria De Souza (Faria De Souza, Luana)

MINUTE entry before the Honorable Jeffrey I Cummings: No remaining defendant has responded to plaintiff's motion for entry of default judgment. Accordingly, the motion [35] is granted. Based on the evidence submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's marks irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $50,000 is an appropriate award of statutory damages. Enter Final Judgment Order. All pending deadlines and hearings are stricken. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Jeffrey I Cummings on 4/18/2025. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 4/18/2025 to Patent Trademark Office, Alexandria VA