2025-cv-01266

COMPLAINT filed by Tottenham Hotspur Limited; Filing fee $ 405, receipt number AILNDC-23051124.

Exhibit 1

SEALED EXHIBIT by Plaintiff Tottenham Hotspur Limited Schedule A regarding complaint[1]

MOTION by Plaintiff Tottenham Hotspur Limited for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tottenham Hotspur Limited

Notice of Claims Involving Trademarks by Tottenham Hotspur Limited

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.

Civil Bond in the amount of $ 10,000.00 check Receipt 100017670 posted by Tottenham Hotspur Limited

NEW PARTIES: Fuzhou Beauideal Trading Co., Ltd., Shenzhen 374 Technology Co., Ltd., Shenzhen Huasheng Clothing Design Co., Ltd., Wenzhou Eco Bags Co., Ltd., Zhanjiang Letong Arts& Crafts Co., Ltd., chengduyusicenmaoyiyouxiangongsi, Gxy Art Gallery, hjltglytk, litunbaihuoshanghang, Print Strends, putianshichengxiangquluchenyangmaoyiyouxiangongsi, rq0710131030x, VA Store89, WangTaoyy, xiangshuopost, yu soccer sport shore, z333, zhaolin maoyi, AoDingDe Co.Ltd, BONTRM, Dibafang Co., Ltd., Dream Snow Co. ltd, FACAIII, FOSHA Jerseys US, Fuheng Electronics Co., LTD, GBAYXJ HOME, GILIGEGE, Haixi Store Co., Ltd., Helenmas, HengRongQi, HHTWRSFD, HXQMJKDUHOA, Jieda Soccer, KAGAYD Co.Ltd, LOONAU, luozheng, LYGFSRDX, piaybook, pxhona, qinshengmaoyi, Runskmd INC, shaotellme shop, SUNGGOKO HOME, UQIANGY HOME, Wiueurtly, Wookpyhgt, WRDMNBV, XDXSSM, Xiangzhong Co., Ltd., XNB STORE, YANPIN, YEGHUN, Yixing Co., LTD, ZEGiudx, ZXIPN, 77footsfr.com, alejersey.com, eurosfootball.com, fardinsoccershop.com, jerseycheng.com, messi105.com, soccershopuk.com and xyong1.com added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

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

MEMORANDUM by Tottenham Hotspur Limited in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

DECLARATION of Matthew Collecott regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Tottenham Hotspur Limited Exhibit 2 - Parts 1-2 regarding declaration 16

Exhibit 2-1

(Exhibit 2-2)

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

MEMORANDUM by Tottenham Hotspur Limited in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

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 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 3/6/2025 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

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Marcella Deshonda Slay

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 3/6/2025. For the reasons stated on the record, 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 [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [18] 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 2 - Parts 1-2 regarding declaration [17]. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:15 a.m. on 3/6/2025 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 3/20/2025 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

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 3/6/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Tottenham Hotspur Limited

Registry Deposit Information Form by Tottenham Hotspur Limited

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

MOTION by Plaintiff Tottenham Hotspur Limited for extension of time of Temporary Restraining Order

MEMORANDUM by Tottenham Hotspur Limited in support of extension of time[28]

DECLARATION of Trevor C. Talhami 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 4/3/2025. Telephonic status hearing set for 3/20/2025 is stricken and reset for 4/3/2025 at 11:15 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 Tottenham Hotspur Limited for preliminary injunction

(Exhibit A)

MEMORANDUM by Tottenham Hotspur Limited in support of motion for preliminary injunction 32

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 33

SUMMONS Returned Executed by Tottenham Hotspur Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/27/2025, answer due 4/17/2025.

Declaration of Jennifer V. Nacht

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/3/2025. 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. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint [2], (2) Exhibit 2 - Parts 1-2 regarding declaration [17], 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 5/8/2025 at 10:00 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 4/3/2025. Mailed notice

NOTICE of Voluntary Dismissal by Tottenham Hotspur Limited as to certain defendants

MOTION by Plaintiff Tottenham Hotspur Limited for entry of default, MOTION by Plaintiff Tottenham Hotspur Limited for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Tottenham Hotspur Limited in support of motion for entry of default, motion for default judgment 39

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment [39] will be heard at the telephonic hearing set for 5/8/2025 at 10:00 AM. Any party wishing to be heard on the motion shall 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

MOTION by Defendant piaybook for extension. (Received via Box.com on 05/07/2025)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/8/2025. For the reasons stated on the record, Defendant piaybook's motion for extension 43 is granted. Defendant piaybook shall answer or otherwise respond to Plaintiff's complaint by 5/28/2025. To avoid default, by 5/28/2025, Defendant piaybook must file an appearance either through counsel or by means of a pro se appearance form. Telephonic status hearing set for 6/4/2025 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 Tottenham Hotspur Limited by Hannah Alexa Abes

ATTORNEY Appearance for Plaintiff Tottenham Hotspur Limited by Madeline Halgren

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/4/2025. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 39 is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/4/2025. Mailed notice

MOTION by Plaintiff Tottenham Hotspur Limited to amend/correct order[48]

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion to amend the default judgment order [48] is granted. Enter Amended Default Judgment Order. Mailed notice

AMENDED DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 9/16/2025. Mailed notice