2025-cv-00908

COMPLAINT filed by Collegiate Licensing Company, LLC; Filing fee $ 405, receipt number AILNDC-23004577.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Schedule A regarding complaint 1

MOTION by Plaintiff Collegiate Licensing Company, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collegiate Licensing Company, LLC

Notice of Claims Involving Trademarks by Collegiate Licensing Company, LLC

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Allyson M. Martin

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Rachel S Miller

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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.

NEW PARTIES: Foshan Nanhai Youpin Chaopai Clothing Store, Foshan Nanhai Yunshang Chengpin Clothing Store (Individual Business), Huizhou Findle Computer Embroidery Co., Ltd., Mingoalone (Dalian) International Trade Co.,Ltd., Shenzhen Gewei Clothing Co., Ltd., Shishi Junxin Garment Accessories Co., Ltd., Wuxi Molis International Trade Company Ltd., Yiwu Beauledo Garment Co., Ltd., Yiwu Queran Clothing Co., Ltd, Zhucheng Licheng Advertising Co., Ltd., Aegean Decor, Chun ye, CYQSHOPONE, DMYPHY, hongdongxiangaojingyimaoyidian, huangdehui0928, huliquzhongzhishuoweibaihuodian, jinanhuimingshangmaoxiaoshouyouxiangongsi, Kazakh communication, Lijinyan., linyi jushifang shangmao youxiangongsi, mingjindedianpu, NEONBOYS, putianshilichengqugongchenjiedaozhengzhihangfuzhua, ROPIC, VBDYTT, Xuguohai, ZSXBH, ZXW123, bahr, brand_88, coosyus, copenssa, ddual, directsports, elevationsports, fans2024, goods002, hot010, jersey24new, jjy1, luckybrands, lululemen1, mamba0824, marca, mylove_jersey, nulipinbo42, ourbest, seller5222, supertopcap, uniformsllz0047, vlone0210, wggood2, yogallz0048, yogallz0049, baxuptxv, castlebl_93, changshayaohengshangmaoyouxiangongsi, choochoong store, CUSTOMALL, CYF, cyril_covey, datongshidufanshangmaozhongxin, diyud30, hho347, huangli6666, iENYRID Official Store, ijryqzii, isidro.c80, janie.-9190, jean.th_47, jody.898, joesph-73, jonas.ric64, jstech24, karin-9463, kirby.65, KKKKD, lawand-5997, liecu-3825, lijin0215, lindbmc-28, lixiang-57, louella.w-56, lplineqq09, madelinestock, Maga America, magallan_18, marco.1606, michele._1594, miguel.-2999, mollie.r29, Movie Basketball Jerseys, mrwt2661, mtf8888, murry-46, ngnguyn-69, ngtran_30, nheidelb_66, NICE GIFT SHOPPING, noemi.8139, Obscure Oasis, oquinn_7, peng88-369, phamtuananh19, phanhu11, phuvo-63, px-fashionest, qhitc26, rainbow_6018, rededica38, reinald_321, rene.s_65, rodneyrussellj, rogelio-2861, safseqe, santalace37, sasha.jo98, selinast2872, su435_55, superseller16888, Suppliers of Rehabilitation Aids, tianyou-49, todou-neon, tovum58, trnv09, trthphn_0, truon_93, tutish, ty-ie003, udshyge, vicki.ha-34, vigth-10, vilma.-48, vofijiaxcraft, wellmanx_51, wenfe-7777, xslagl-1, xulin_2169, yangzheng1718, yiche_2885, yiku_1095, youbao_54, ZB-Zhenbiao, zgill_71, CSAXEDZSWLLC, Funnystore, Gokawyo, Gruiyong, guangxichengdazhonggongyouxiangongsi, Kemisports inc, Liuzhiling, MinLi, PTZETIAN, tuhuism, YanTaiYuanLu, Yifandianzi, Zhi Hao auto partsstore, rugbychampions.club, topsmartdesign.com and chengke3199 added to case caption.

MAILED original twelve thousand-dollar ($12,000) surety bond [29] posted by Justin R. Gaudio, Greer, Burns & Crain Ltd. 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7834 24.

MAILED original twelve thousand-dollar ($12,000) surety bond [29] posted by Justin R. Gaudio, Greer, Burns & Crain Ltd. 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7834 24.

MAILED original twelve thousand-dollar ($12,000) surety bond 29 posted by Justin R. Gaudio, Greer, Burns & Crain Ltd. 200 West Madison St., Suite 2100, Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7834 24.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 3 is granted. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff Collegiate Licensing Company, LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for temporary restraining order 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Lindsay Conn regarding memorandum in support of motion 15

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Exhibit 1 regarding declaration 17

DECLARATION of Sterling Hawkins regarding memorandum in support of motion 15

(Exhibit 1)

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

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for miscellaneous relief 20

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

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold and shipped at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte telephone conference held on 2/10/2025. Transcript is to remain sealed. Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 2/10/2025. Mailed notice.

Registry Deposit Information Form by Collegiate Licensing Company, LLC

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

INJUNCTION BOND in the amount of $12,000 posted by Collegiate Licensing Company, LLC (Document not scanned).

MOTION by Plaintiff Collegiate Licensing Company, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Collegiate Licensing Company, LLC in support of extension of time 30

(Declaration of Allyson M. Martin)

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order 30 is granted. The Temporary Restraining Order entered on 2/10/2025 is extended by a period of fourteen (14) days until 3/10/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Collegiate Licensing Company, LLC as to a Certain Defendant

MOTION by Plaintiff Collegiate Licensing Company, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for preliminary injunction 34

(Declaration of Allyson M. Martin)

SUMMONS Returned Executed by Collegiate Licensing Company, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/5/2025, answer due 3/26/2025.

Declaration of Rachel S. Miller

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 34 is set for 3/10/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 3/10/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibits to the Declaration of Lindsay Conn 18, and the TRO 25. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 4/23/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 3/10/2025. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 4/23/2025. A telephone status hearing is set for 6/3/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Collegiate Licensing Company, LLC to approve consent judgment as to Certain Defendants

Exhibit A

MOTION by Plaintiff Collegiate Licensing Company, LLC for entry of default as to all Remaining Defendants, MOTION by Plaintiff Collegiate Licensing Company, LLC for default judgment as to all Remaining Defendants

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for entry of default, motion for default judgment, [42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 6/3/2025 at 9:15 a.m. is converted to a telephone hearing on the motion for entry of default and default judgment [42]. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for entry of consent judgment as to certain defendants [41] is granted. Mailed notice.

CONSENT Judgment. Signed by the Honorable Thomas M. Durkin on 5/28/2025. Mailed notice.

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Rachel Meira Ackerman

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 6/3/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and default judgment [42] is granted. Enter order. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 6/3/2025. Mailed notice.

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

Closing Minute Entry dated 6/3/2025

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7834 24.

FULL SATISFACTION of Judgment regarding order 51 in the amount of $200,000 as to certain defendants