2025-cv-00661

COMPLAINT for Copyright Infringement filed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD; Jury Demand. Filing fee $ 405, receipt number AILNDC-22972790.

Exhibit 1 to the Complaint

(Exhibit 2 to the Complaint)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Shawn Anthony Mangano

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Gokalp Bayramoglu

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 3).

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 Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 3).

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.

NEW PARTIES: BESRXXS, MOJICK, Ramdjalo, Waasmia and YAOMEI added to case caption.

Terminating Ramdjalo, Waasmia, YAOMEI, BESRXXS and MOJICK

MAILED Copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff is put on notice that it may be required to file a memorandum discussing the propriety of joinder under Federal Rule of Civil Procedure 20(a)(2) if it appears that defendants are too numerous or unconnected. In addition, should default judgment enter against defendant(s), Plaintiff should be prepared to prove up damages by affidavit or hearing. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD for leave to file excess pages IN SUPPORT OF PLAINTIFFS MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD for temporary restraining order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION

Declaration of Katherine M. Kuhn ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Exhibit 6 to the Declaration of K. Kuhn

Exhibit 7 to the Declaration of K. Kuhn

Declaration of Katherine M. Kuhn ISO Temporary Restraining Order Regarding Purch

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for temporary restraining order, [12] before Honorable Sharon Johnson Coleman on 1/29/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 1/29/2025. Upon review of the Complaint, the Court questions whether joinder of 20 defendants is appropriate in this case. See, e.g. Estee Lauder Cosmetics Ltd. v. Schedule A, Case No. 19-cv-7878, 2020 WL 433870 (N.D. Ill. Jan. 27, 2020) (Chang, J.). Plaintiff shall file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. In addition, Plaintiff has leave to file an amended complaint with smaller subset of defendants along with its memorandum. Plaintiff's motion to exceed page limitation in support of plaintiff's motion for entry of a temporary restraining order [11] and motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication [12] are entered and continued. Mailed notice.

MOTION by Attorney Shawn A. Mangano to withdraw as attorney for Hong Kong Leyuzhen Technology Co., LTD. No party information provided

MINUTE entry before the Honorable Sharon Johnson Coleman: Attorney Shawn A. Mangano's motion for leave to withdraw as counsel of record [15] is granted. Attorney Shawn Anthony Mangano terminated. All counsel of record is reminded that pursuant to LR 5.3 and this Court's standing orders, all motions are to be noticed up for presentment before this Court. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: An in-person status hearing is set for 3/5/2025 at 10:00 AM. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD to reset March 5, 2025 Status Hearing

Exhibit A to the Motion to Reset the Status Hearing

NOTICE of Motion by Joseph Wendell Droter for presentment of

MINUTE entry before the Honorable Sharon Johnson Coleman: Plaintiff's motion to reset status hearing [18] is granted. No appearance necessary on 2/26/2025. The in-person status hearing set for 3/5/2025 is stricken and reset to 3/7/2025 at 9:45 AM. Mailed notice.

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co., LTD against Hong Kong Leyuzhen Technology Co., LTD for Copyright Infringement

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

SUPPLEMENT to amended complaint, [21], order on motion for leave to file excess pages, order on motion for temporary restraining order, motion hearing, [14] Supplemental Brief in Compliance with Docket 14

Declaration of Katherine M. Kuhn ISO Supplemental Brief

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Declaration of Joseph W. Droter ISO Supplemental Brief

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 3/7/2025. Plaintiff's motion to exceed page limitation in support of motion for entry of a temporary restraining order [11] and motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by e-mail and/or electronic publication [12] are taken under advisement. Counsel is to submit a revised proposed order to the Court's proposed order email for review. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: The Court has reviewed the plaintiff's revised proposed order and grants the motion to exceed page limitation in support of motion for entry of a temporary restraining order [11] and motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by e-mail and/or electronic publication [12]. Enter Order. An in-person status hearing is set for 3/25/2025 at 10:00 AM. Mailed notice.

TEMPORARY Restraining Order. Signed by the Honorable Sharon Johnson Coleman on 3/11/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) batelibags by Plaintiff Hong Kong Leyuzhen Technology Co., LTD

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD to deposit funds

Exhibit Registry Deposit Information Form

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion to deposit funds[28] before Honorable Sharon Johnson Coleman on 3/25/2025 at 10:00 AM.

NOTICE of Correction regarding summons issued (court participant)[27]

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co., LTD as to Hong Kong Leyuzhen Technology Co., LTD on 3/19/2025, answer due 4/9/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD for preliminary injunction

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION

Declaration OF JOSEPH W. DROTER, ESQ. IN SUPPORT OF

Exhibit 1 to the DECLARATION OF JOSEPH W. DROTER, ESQ. IN SUPPORT OF

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [33] before Honorable Sharon Johnson Coleman on 3/25/2025 at 10:00 AM.

INJUNCTION BOND in the amount of $ 5,000 posted by Hong Kong Leyuzhen Technology Co., LTD (Document not scanned)

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 3/25/2025. Because the plaintiff has already entered the bond, plaintiff's motion to deposit funds [28] is moot. Counsel reported that summons in this case were served on March 19, 2025, the Court enters and continues the motion for entry of a preliminary injunction [33]. Oral motion by plaintiff to extend the temporary restraining order is granted. The Temporary Restraining Order is extended to April 9, 2025. An in-person status hearing is set for 4/9/2025 at 10:00 AM. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/9/2025. Defendants did not appear nor contact the Court. For the reasons stated in court, plaintiff's motion for preliminary injunction [33] is entered and continued to 4/23/2025 at 9:00 AM as an in-person hearing. Oral motion by plaintiff for an extension of the Temporary Restraining Order is granted to 4/23/2025. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Due to the Court's trial calendar, the in-person presentment hearing set for 4/23/2025 at 9:00 AM is reset to 8:45 AM (NOTE TIME CHANGE ONLY). Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 4/23/2025. Defendant did not appear nor contact the Court. Plaintiff's motion for preliminary injunction [33] is granted. Enter Order. An in-person status hearing is set for 5/23/2025 at 10:00 AM. Law Firm of Bayramoglu Law Offices LLC 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

ORDER FOR PRELIMINARY INJUNCTION. Signed by the Honorable Sharon Johnson Coleman on 4/23/2025. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD for default judgment as to Defendant batelibags

Exhibit Memorandum in SUpport of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

Declaration of Joseph W. Droter in Support of Motion for Default and Default Jud

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [41] before Honorable Sharon Johnson Coleman on 6/11/2025 at 10:00 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., LTD to reset 5/23/25 Status Hearing to Wednesday, June 11, 2025 10:00 am

MINUTE entry before the Honorable Sharon Johnson Coleman: Status hearing held on 5/23/2025. Counsel for plaintiff reported that a motion for default judgment has been filed [41] and is noticed up for 6/11/2025 at 10:00 AM. The Court will enter and continue the motion to 6/11/2025. Plaintiff's motion to reset May 23, 2025, status hearing [43] is stricken as moot. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Presentment of plaintiff's motion for entry of default and default judgment [41] set for 6/11/2025 at 10:00 AM is reset to 9:15 AM (NOTE TIME CHANGE ONLY) and will proceed as an in-person hearing in courtroom 1241. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 6/11/2025. Defendants did not appear for the in-person hearing nor contact the Court. Plaintiff's motion for entry of default and default judgment [41] is granted. As stated on the record, plaintiff's attorney will not be seeking attorney's fees in the event the Court grants its request for statutory damages, which it does so here. The Court grants statutory damages in the amount of $750. Default judgment is entered in favor of plaintiff and against the defendant batelibags. Enter Final Judgment Order. Civil case terminated.Mailed notice

FINAL DEFAULT JUDGMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 6/13/2025. Mailed notice.