2025-cv-01375

COMPLAINT for Copyright Infringement filed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD; Jury Demand. Filing fee $ 405, receipt number AILNDC-23062635.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Complaint for Copyright Infringement regarding complaint, 1

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal for Leave to File Under Seal

Declaration of Katherine M. Kuhn ISO Motion for Leave to File Under Seal

(Exhibit 1 to the Declaration of K. Kuhn)

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal for Leave to File Under Seal 4

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 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 Jorge L. Alonso. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 3). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 3/18/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

Exhibit Memorandum in Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn ISO Motion for Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages in Support of Temporary Restraining Order

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

Exhibit Memorandum of Law in Support of Temporary Restraining Order

Declaration of Katherine M. Kuhn ISO 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

Declaration of Liangjie Li ISO Temporary Restraining Order

Exhibit 1 to the Declaration of L. Li

Declaration of Emily M. Heim ISO Temporary Restraining Order

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for service by publication, [13], motion for temporary restraining order, [15] before Honorable Jorge L. Alonso on 3/18/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff has filed a motion for temporary restraining order and other related motions, [4] [13] [14] [15], without submitting a proposed order consistent with this Court's procedures or explaining why the Court should deviate from its practice of assessing a bond of $1,000 per Defendant should the motions be granted. No later than 5:00 PM CT today, Plaintiff shall submit a proposed order along with a redline consistent with the procedures set forth on the Court's website, which should make clear whether Plaintiff is amenable to posting a bond of $1,000 per Defendant if the Court is inclined to grant the requested relief. The motion hearing set for 3/18/25 is reset for 3/19/25 at 9:30 AM. Plaintiff's counsel is cautioned that the Court expects strict compliance with its procedures going forward. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for leave to file under seal [4] is granted. Plaintiff's Motion for electronic service of process [13] is granted. Plaintiff's Motion to exceed page limitation in support of Plaintiff's motion for entry of a temporary restraining order [14] is granted. Plaintiff's Ex Parte Motion for entry of a temporary restraining order [15] is granted. Telephonic status hearing set for 4/2/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 3/19/2025. Notice mailed by Judge's staff

SUMMONS Submitted (Court Participant) for defendant(s) THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A HERETO by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

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. Limited to deposit funds

Exhibit Registry Deposit Information Form

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion for leave to deposit funds into court registry [22] is granted. Enter Order granting Plaintiff's Motoin for leave to deposit funds into court registry. Notice mailed by Judge's staff

ORDER Granting Plaintiff's Motion For Leave To Deposit Funds Into Court Registry. Signed by the Honorable Jorge L. Alonso on 3/27/2025. Notice mailed by Judge's staff

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time of TEMPORARY RESTRAINING ORDER

MEMORANDUM IN SUPPORT OF PLAINTIFFS FIRST MOTION TO EXTEND TEMPORARY RESTRAININ

Declaration of J. Droter in Support of Motion to Extend TRO

NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [25] before Honorable Jorge L. Alonso on 4/2/2025 at 09:30 AM.

INJUNCTION BOND in the amount of $43,000 posted by Hong Kong Leyuzhen Technology Co. Limited (Document not scanned)

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's First motion to extend the temporary restraining order [25] is granted. the temporary restraining order is extended to 4/16/25. Motion hearing date of 4/2/25 is stricken. Telephonic status hearing previously set for 4/2/25 is stricken and reset to 4/16/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 4/4/2025, answer due 4/25/2025.

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

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION

Declaration of J. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration J. Droter in Support of Motion for Preliminary Inju

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [30] before Honorable Jorge L. Alonso on 4/16/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited as to Defendants 23 and 42

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 5/15/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for preliminary injunction [30] is granted. Enter Preliminary Injunction Order. Plaintiff 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 at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 4/16/2025. Notice mailed by Judge's staff

NEW PARTIES: Little WildcatLM, ZIBUYU, ANGELS storenbhu, Budget Couture, CHAOLILAI, Curvy Inventory, DAISY SUNSHINE, DHRYRBHC SHOP, Dongguan Yujian Appa, Enjoymall, Ginoa, HAPPY GIRL'S CLOTHES, Ideal wardrobe, Inpetal, Kaibom, Large size, Love You So, luckbea, Majestical Gems, Mermaid princess, MT Swimwear, SEXYAPPAREL23, SOFIAPS CHOICE, Soulfulearthcraft and Taryndoria added to case caption. (Text entry; no document attached.)

NEW PARTIES: ValueFashionShop, Yewaysz, YuHan., XWD Find Pretty, Abovebuy, GemaRosie59, Meitz womens wear, Bigger and stronger, WZQBBC, ABLE FASHION, Colorful seaside, Mytelite Shop, WAQBBC, witkey minmin, Ahn'Qiraj, FOXCLAW Curve, RoseWe and Sepchir added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 37 Defendants

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default Judgment

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [35] before Honorable Jorge L. Alonso on 5/6/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co. Limited ONLY as to Defendants 13, 16, 21 and 36

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/6/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against the identified schedule "A" Defendants [35] is granted. Enter Final Default Judgment Order. Status hearing previously set for 5/15/25 is stricken. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 5/6/2025. Notice mailed by Judge's staff

ATTORNEY Appearance for Defendants FOXCLAW Curve, Love You So, Ahn'Qiraj by Ruixin Lu

NOTICE of Motion by Ruixin Lu for presentment of before Honorable Jorge L. Alonso on 5/27/2025 at 09:30 AM.

MOTION by Defendants Ahn'Qiraj, FOXCLAW Curve, Love You So to vacate Default Judgement and Extension of Time to Answer

Declaration of Yaoli Zheng

Exhibit A of Declaration of Yaoli Zheng

Declaration of Jianjian Wei

Exhibit A of Declaration of Jianjian Wei

Exhibit B of Declaration of Jianjian Wei

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to set a briefing schedule on Defendants' Motion to Vacate Default Judgment

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion to set briefing schedule [44] is granted. Plaintiff's response to Defendant No. 40, 41 and 17's Motion to vacate default judgment and extension of time to answer [43] shall be filed by 6/13/25; Defendants' reply shall be filed by 6/27/25. Motion hearing date of 5/27/25 is stricken. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order[40] ONLY as to Defendant 11

RESPONSE by Hong Kong Leyuzhen Technology Co. Limitedin Opposition to MOTION by Defendants Ahn'Qiraj, FOXCLAW Curve, Love You So to vacate Default Judgement and Extension of Time to Answer [43] Combined Opposition to Motion to Vacate Default Judgment and Motion to Strike Under Fed.R.Evid. 408

REPLY by Ahn'Qiraj, FOXCLAW Curve, Love You So to response in opposition to motion, [47]

Declaration of Jianjian Wei

Declaration of Yaoli Zheng

MINUTE entry before the Honorable Jorge L. Alonso: Defendants Ahn'Qiraj/FOXCLAW Curve, FOXCLAW Curve, and Love Youmove [43] move to vacate the default judgment entered against them at [40]. Under Federal Rule of Civil Procedure 60(b), a "court may relieve a party or its legal representative from a final judgment, order or proceeding for. mistake, inadvertence, surprise, or excusable neglect. [or] any other reason that justifies relief." Here, Defendants are based internationally and argue that their delay in appearing was due to excusable neglect or surprise because they were actively negotiating a settlement prior to the motion for default being filed, but the motion was filed and granted during a Chinese labor holiday, which gave them no time to respond to the motion. ECF No. 43 at 2. They also contend that although they had total alleged infringing sales of about $12,000 combined, Plaintiff sought and received a much higher penalty of approximately $126,000, and that such a judgment was entered inadvertently in the absence of the adversarial process. Id. at 3-4, 10. Schedule A cases present unique challenges in that plaintiffs seek relief against large numbers of online, international defendants. Given these circumstances, defendants rarely appear, and Schedule A cases are often resolved through default judgments. But the Seventh Circuit "has a well established policy favoring a trial on the merits over a default judgment." Sun v. Bd. of Trs. of Univ. of Illinois, 473 F.3d 799, 811 (7th Cir. 2007). Here, the Court finds that the interests of justice would be served by vacating the default judgment as to these Defendants and allowing the case to proceed on the merits. For this reason, the motion [43] to vacate the default judgment is granted and this case is reopened. In addition, the Court declines to strike the references to settlement offers and negotiations because it interprets the information as going to whether there was excusable neglect or surprise from the entry of the default judgment rather than "the validity or amount of a disputed claim." Fed. R. Evid. 408. The parties shall file a joint status report by 9/25/25 providing the Court with proposed deadlines for next steps in the litigation, whether they wish for the Court to schedule a settlement conference, and whether a bond must be paid in these circumstances. The Court sets a telephonic status conference for 10/1/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

STATUS Report in Compliance with Docket 49 by Hong Kong Leyuzhen Technology Co. Limited

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 10/16/25 at 9:30 a.m. If a stipulation to dismiss is filed in advance of that date, no one needs to appear on 10/16/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff