2025-cv-00618

COMPLAINT filed by Lululemon Athletica Canada Inc.; Filing fee $ 405, receipt number AILNDC-22970655.

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Schedule A regarding complaint 1

MOTION by Plaintiff Lululemon Athletica Canada Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lululemon Athletica Canada Inc.

Notice of Claims Involving Trademarks by Lululemon Athletica Canada Inc.

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Andrea R. Wood. 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.

BOND in the amount of $10,000.00 check, Receipt #100016677, posted by Lululemon Athletica Canada Inc. (qrtr,)

NEW PARTIES: Dantle Sports Goods (shenzhen) Co., Ltd., Dongguan City Chuangwei Textile Co., Ltd., Dongguan Huixin Apparel Co., Ltd., Dongguan Jijie Apparel Co., Ltd., Fujian Kangke Electronic Technology Co., Ltd., Gansu Dongshengyuan Trading Co., Ltd., Guangdong Yatai International Garment Develop Co., Ltd., Guangzhou Chiyi Industrial Co., Ltd., Guangzhou Ouerman Garment Co., Ltd., Guangzhou Sanxuanshi Trading Co., Ltd., Guangzhou Tongyuan Knitting Co., Ltd., Guangzhou Yida Technology Co., Ltd., Hangzhou Fuhan Garment Accessories Co., Ltd., Hangzhou Xianpu Trading Co., Ltd., Henan Zhenhuan Trading Co., Ltd., Jinan Kyger Trading Co., Ltd., Longgang City Dayou Packing Co., Ltd., Longgang Youjing E-Commerce Firm, Nanchang World Apparel Co., Ltd., Sanya Yuantron Trading Co., Ltd., Shaoxing Suerte Textile Co., Ltd., Sheyang Jiayun Huiyan Technology Co., Ltd., Wenzhou Fuyun Crafts Co., Ltd., Wenzhou Hela Packaging Co., Ltd., Wuhan Jinteng Manufacturing & Trading Co., Ltd., Xiamen Bagthink Imp & Exp Co., Ltd., Xiamen Sandra Sports Trading Co., Ltd., Yiwu Linglan Luggage Co,ltd, Yiwu Siyu Import and Export Co., Ltd., Yiwu Yandian Trading Company Limited, ChaoqiangC, Gacaky, KTILG, LASLULU, Locachy, MengJStore, Ncvtang, guan07, lulu5566, OFF FOR ALL, zhangxuanang, 88fw1ef, aegfwe15, b53614-954, big7459, bnd4461, bus-7558, chenzong3761, drftjh188, dudu477w, gayingshang-0, guangzhoukunqisha-0, hdsfds5412, iqsfs54004gg, jinanyuezhuodianzi-0, kp7786, lianghui-6, lilianzhui, lingfeng2f, litaoshangmaoy, mingping_zhneg, morlife2019, pao1722, poygeasxcc77, rtfghnm7410, sdvbsbf1, skyline8655, vsrc-30, xshgfh62, yingbing2 and zhengzhouhangsongsh-0 added to case caption.

MOTION by Plaintiff Lululemon Athletica Canada Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Jenny Vo regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 4 Parts 1-3 regarding declaration[14]

MOTION by Plaintiff Lululemon Athletica Canada Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for miscellaneous relief[16]

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] are set for a telephonic motion hearing on 2/12/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Rachel S Miller

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 2/12/2025. For the reasons stated on the record, Plaintiff's motion for leave to file certain documents under seal [3], ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint [2], and (2) Exhibit 4, Parts 1-3 regarding declaration [15]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 9:00 a.m. on 2/12/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 2/26/2025 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

SEALED ORDER Signed by the Honorable Andrea R. Wood on 2/12/2025. Mailed notice

Registry Deposit Information Form by Lululemon Athletica Canada Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Lululemon Athletica Canada Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Plaintiff Lululemon Athletica Canada Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Lululemon Athletica Canada Inc. in support of extension of time[28]

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order [28] is granted. The Court finds good cause to extend the Temporary Restraining Order an additional 14 days until 3/12/2025. Telephonic status hearing set for 2/26/2025 is stricken and reset for 3/12/2025 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

MOTION by Plaintiff Lululemon Athletica Canada Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for preliminary injunction[32]

Declaration of Kahlia R. Halpern

SUMMONS Returned Executed by Lululemon Athletica Canada Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/5/2025, answer due 3/26/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction [32] will be heard at the telephonic hearing set for 3/12/2025 at 10:15 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Marcella Deshonda Slay

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/12/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [32] is granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. Plaintiff is granted leave to file the spreadsheet under seal. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 4, Parts 1-3 regarding declaration [15], and (3) the sealed temporary restraining order [24]. Plaintiff's counsel 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 4/16/2025 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 3/12/2025. Mailed notice

ATTORNEY Appearance for Defendant LASLULU by Steven G Kalberg

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to certain defendants

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-23338087. Defendant KTILG

MINUTE entry before the Honorable Andrea R. Wood: Motion to appear pro hac vice [42] is granted. Mailed notice

MOTION by Defendant KTILG for extension of time to file response/reply as to complaint[1] Unopposed

MINUTE entry before the Honorable Andrea R. Wood: Defendant KTILG's unopposed motion for extension of time to respond to complaint [44] is granted. Defendant KTILG shall answer or otherwise respond to the complaint by 4/29/2025. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing set for 4/16/2025 is stricken and reset for 5/7/2025 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to certain defendants

MOTION by Defendant KTILG to dismiss for lack of jurisdiction

Certificate of Service

Certificate of Service

Declaration

MINUTE entry before the Honorable Andrea R. Wood: The Court will set a briefing schedule on Defendant KTILG's motion to dismiss complaint [48] at the telephonic status hearing set for 5/7/2025 at 10:45 AM [46]. Mailed notice

CERTIFICATE of Compliance with The Lanham Act Mediation Program

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/7/2025. As stated on the record, by 5/14/2025, the parties shall meet and confer and file a joint status report setting forth: (1) a status on any outstanding disputes regarding discovery, and (2) a proposed briefing schedule on the pending motion to dismiss. Telephonic status hearing set for 5/21/2025 at 11:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

TRANSCRIPT OF PROCEEDINGS held on May 7, 2025 before the Honorable Andrea R. Wood. Order Number: 51851. Court Reporter Contact Information: Brenda Varney, CSR, RMR, CRR, brenda_varney@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 6/3/2025. Redacted Transcript Deadline set for 6/13/2025. Release of Transcript Restriction set for 8/11/2025.

STATUS Report (Joint) by Lululemon Athletica Canada Inc.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

MOTION by Defendant KTILG for leave to file Amended Motion to Dismiss

Exhibit

(Exhibit)

MEMORANDUM by KTILG in support of motion for leave to file 54

MOTION by Defendant KTILG to dismiss for lack of jurisdiction PROPOSED AND OPPOSED

MEMORANDUM by KTILG in support of motion to dismiss/lack of jurisdiction 56 PROPOSED AND OPPOSED

Exhibit A

Exhibit B

Exhibit C

Exhibit D

(Exhibit E)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/21/2025. For the reasons stated on the record, the pending motions at docket nos. [48], [54], and [56] are entered and continued. Telephonic status hearing set for 6/11/2025 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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

NOTICE of Voluntary Dismissal by Lululemon Athletica Canada Inc. as to certain defendants

STIPULATION of Dismissal (Joint)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/11/2025. For the reasons stated on the record, the pending motions at docket nos. [48], [54], and [56] are terminated as moot. Telephonic status hearing set for 6/25/2025 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. (jn,)

MOTION by Plaintiff Lululemon Athletica Canada Inc. for entry of default, MOTION by Plaintiff Lululemon Athletica Canada Inc. for default judgment as to all remaining Defendants

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for entry of default, motion for default judgment, [61]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[62]

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Telephone conference held on 6/25/2025. No Defendants appear. Plaintiff's motion for entry of default and default judgment [61] is taken under advisement. A telephonic status hearing set for 7/11/2025 at 10:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. (jn,)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment [61] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/30/2025. Mailed notice

Full SATISFACTION of Judgment regarding order[67] in the amount of $500,000 as to certain defendant

MAILED trademark report with certified copy of minute order dated 6/30/2025 to Patent Trademark Office, Alexandria VA. (jn,)