2025-cv-02193

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 405, receipt number AILNDC-23152633.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Christopher Romero

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Monica Rita Martin

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ground Works Co., Ltd., Khara Inc.

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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: JasonQ Supply LLC, JiaFeng Trading Store, ladyxuemei, Lincanghanchongfeng, liuyangshixuejunyuebaihuoyouxiangongsi, LUONGSHOP788, Manning US Store, Marmota Geek, NHI 2001 SHOP, oufangjunnnnn, Self typing, songniyiduoxiaohonghua, Stoihhu, Sumgsn, TAYOKII, TEAM WORKER, weimoumaiguangguangou, weishansea, YANYANZHEN, YMDK, yunjiayimaoyi, AOC ORGANIC VIETNAM COMPANY LIMITED, BAO KHANH LTD, CENOYEE, DIEU KHANG LTD, DUTA GLOBAL- Eastern-Print, foshanshichongjidishangmao, guangzhouchenfashangmaoyouxiangongsi, guangzhouruishimaoyiyouxiangongsi, Helping Homies, 32 KenGifts, Lux Outlet Store, LYBALYBO, NEXGEN BROS COMPANY LIMITED, omagie, PQ EMBROIDERY COMPANY LIMITED, Roffatide, SH SAI GON, SHUNYIKEJI, Suave Tees, Superwoman shop, taininuomaoyi, XingFashion, XTCXJC, XTCYYX, yingxinizhinengjiaju and Defendant 25 added to case caption.

MAILED original forty-seven-thousand-dollar ($47,000) surety bond posted by Khara Inc. and Ground Works Co., Ltd. to Jiangip Llc 33 West Jackson Boulevard Unit #2W Chicago, IL 60604 via certified mail # 9589 0710 5270 0579 7845 20.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable John J. Tharp, Jr: By 4/11/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Minute entry [14] is corrected as follows: By 3/11/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file under seal

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file excess pages

MEMORANDUM in Support of [18] Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Yasuhiro Kamimura

Exhibit 1, of Yasuhiro Kamimura's Declaration

SEALED EXHIBIT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Sealed Exhibit 2, Declaration of Yasuhiro Kamimura regarding memorandum in support of motion, [19]

SUPPLEMENT to Supplemental Information to Plaintiff's Motion [18] for Temporary Restraining Order

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order [18] is taken under advisement. By 3/18/2025, the plaintiff is required to supplement its motion with an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. The plaintiff's motions for leave to file certain exhibits under seal [16] and to file excess pages [17] are both granted. Mailed notice

SUPPLEMENT to Supplemental Information in Support of Plaintiff's Ex Parte Motion for Temporary Restraining Order [18] and Pursuant to Minute Entry Order [22]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiffs' ex parte motion for TRO [18] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 3/18/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) JasonQ Supply LLC by Plaintiffs Ground Works Co., Ltd., Khara Inc.

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

SURETY BOND in the amount of $ 47,000 posted by Ground Works Co., Ltd., Khara Inc. (Document not scanned).

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for preliminary injunction

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for preliminary injunction[29]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/26/2025, answer due 4/16/2025.

Declaration of Service

Exhibit 1, of Declaration of Service

Exhibit 2, of Declaration of Service

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 29 is taken under advisement. Any objection or response is due before 3/31/2025. Upon review of the declaration of service, the Court directs the plaintiff, by 3/28/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 3/31/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The deadline for objections or responses to the plaintiff's motion for preliminary injunction [29] having passed, the plaintiff is directed to file a declaration of service verifying that it complied with the Court's instructions of 3/27/2025 [32]. The declaration of service must be filed no later than 4/3/2025. Mailed notice

DECLARATION of Service regarding text entry, [33]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [29] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 4/5/2025 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 4/2/2025. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 37, defendant no. 1, 2, 7, 16, and 38 are dismissed without prejudice. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 14 Sumgsn

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for default judgment as to the Defendants Identified in First Amended Schedule A

Exhibit 1

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment[40]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 39, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 14 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's motion for entry of default and default judgment 40 is taken under advisement. Any objections or responses are due by 4/28/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 4/21/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this Order, and containing a link to the updated website. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 11 Self typing and defendant no. 20 YMDK

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiffs' notice of voluntary dismissal [44], and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 11 and 20 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiffs' motion for default judgment [40] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 4/30/2025. Mailed notice

MAILED trademark report with order dated 4/30/2025 to Patent Trademark Office, Alexandria VA

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7845 20. (Received by mail in the Clerk's Office on 5/9/2025)