2025-cv-01535

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-23082122.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mattel, Inc. regarding complaint[1]

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

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.

Order on Motion for Extension of Time

NEW PARTIES: Dezhou Resup Import & Export Co., Ltd., Xiamen Yaoraoxiannv Trading Co., Ltd., A35YB94HCEKW3T, A3JRIN4ZLX126C, A3OIY1PJL77V92, Aokiya Store, BaizxShop, caoxianjiataifushi, changyibaihuodian, chengjiangwanghuiwangluokejiyouxiangongsi, DeceMars Lash, DoDo Store US, feihongwu, FORWOMLM, foshanshizhixinshangmaogongzuoshi, Fotele, GDJGTA, Guangzhouyangzhoushangmaoshanghanggerenduzi, GUWHOUN, hezaomaoyi, JTFIL Eyelashes, Juliana Jewel, KukuBear, Kunsecsh US, liuheeg, LUOLEPINGSHOP, Metal Group, Oulac, OYSRONG, PartyZoneWig, prince2022, PUSHPEEL, putianshichengxiangquchenhongfeixiangbaojingyingbu, Shengsu-us, STSEETOP, superber, Toolboxes, TOP ICY JEWELRY, US ShengZi, Vayuixue, VENALISA Official Store, Waillynice, WANT TRADE, WaterGroup, wuhuarongyun, WuLuMuQiKeRuiYuanDaDianZiKeJiYouXianGongSi, XIAOPAN DEDIAN, Xingyu Hang Wall Art, Yanpng, YouXiShangMao68, yulianghaishangmao, ZHUXIU-HOME, austin-yk, BeibeiStore1, Bungolawing, Chinese wholesaler supermarket, cmmmmshop, dyjt006, jghjg89, pingdingcaixinsha-0, qa2000, qisisakurastyleclothing, rainbow023, ruyu6010, weikecn, yituifly, Yunhong-Shop, chenyu, Creamily Hair, CrocsGlam USA, QUEENTAS Hair Wigs, ROKR Technology Co.,Ltd and UNIH added to case caption.

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by February 20, 2025, the Court may dismiss this matter for failure to prosecute. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by February 21, 2025, the Court may dismiss this matter for failure to prosecute. Mailed notice.

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

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[13]

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

DECLARATION of Michael Moore regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mattel, Inc. regarding declaration[16]

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

MEMORANDUM by Mattel, Inc. in support of motion for miscellaneous relief[18]

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

SEALED DOCUMENT by Plaintiff Mattel, Inc. Schedule A Template per [12]

Registry Deposit Information Form by Mattel, Inc.

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

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

INJUCTION BOND in the amount of $ 10,000 posted by Mattel, Inc. (Document not scanned).

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[28]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[29]

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to extend the TRO 28 is granted. The TRO is extended to March 20, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction[33]

Declaration of Rachel S. Miller

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/17/2025, answer due 4/7/2025.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [33] for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by March 21, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff Mattel, Inc. regarding order on motion for preliminary injunction, text entry, [36]

Exhibit A

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MINUTE entry before the Honorable Beth W. Jantz: Plaintiff's motion for a preliminary injunction [33] is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established [37] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Signed by the Honorable Lindsay C. Jenkins on 3/24/2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: By April 10, 2025, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment[45]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[46]

Exhibit 1

ATTORNEY Appearance for Defendant chenyu by Adam Edward Urbanczyk

MOTION by Defendant chenyu for extension of time UNOPPOSED

ATTORNEY Appearance for Defendant Fotele by Zhiwei Hua

MOTION by Defendant Fotele for extension of time to file answer regarding summons returned executed[35]

ATTORNEY Appearance for Defendant Bungolawing by Adam Edward Urbanczyk

MOTION by Defendant Bungolawing for extension of time UNOPPOSED

MINUTE entry before the Honorable Lindsay C. Jenkins: The motions by Defendants Bungolawing, Fotele and chenyu [49] [51] [53] are partly granted. These Defendants' responsive pleadings are now due by May 2, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following Order does not apply to Defendants Bungolawing, Fotele and chenyu. Before the Court is Plaintiff's motion [45] for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before April 21, 2025. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by April 18, 2025. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff Mattel, Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, [55]

Exhibit A

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

ATTORNEY Appearance for Defendant feihongwu by Adam Edward Urbanczyk

MOTION by Defendant feihongwu for extension of time UNOPPOSED

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant feihongwu's unopposed motion for an extension of time [59] is granted. This Defendant's responsive pleading is now due by May 13, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following Order does not apply to Defendants feihongwu, Bungolawing, Fotele and chenyu. These Defendants' responsive pleadings remain due by May 2, 2025. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [45] is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. Enter Final Judgment Order. Mailed notice.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Lindsay C. Jenkins on 4/22/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

FULL SATISFACTION of Judgment regarding order[62] in the amount of $100,000 as to certain defendants

NOTICE of withdrawal of bond [27] by John Summerfield

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendant

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Chenyu's answer was due by May 2, 2025, but nothing was filed. [54]. Any motion for default or stipulation of dismissal must be filed by May 9, 2025. Defendant feihongwu's responsive pleading remains due by May 13, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to certain defendants

MOTION by Plaintiff Mattel, Inc. to stay All Deadlines and Notice of Settlement (Joint)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff and the final Defendant chenyu have reached a settlement but need more time to finalize their agreement. The matter is dismissed without prejudice. The dismissal will automatically convert to a dismissal with prejudice on June 23, 2025 unless any party files a motion to reinstate by that date. The parties are free to file a stipulation of dismissal with prejudice earlier if they wish. Civil case terminated. Mailed notice.

STIPULATION of Dismissal as to a Certain Defendant