2025-cv-02214

COMPLAINT filed by Hallmark Licensing, LLC ; Filing fee $ 405, receipt number AILNDC-23154947.

Exhibit 1

Exhibit 1

Exhibit A

Exhibit A

Declaration of Madeline B. Halgren

Exhibit A

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit 1

Exhibit 1

Exhibit Ex. 1 - Defendants Document Production

Exhibit Ex. 1 - Defendants Document Production

SEALED EXHIBIT by Plaintiff Hallmark Licensing, LLC Schedule A regarding complaint[1]

Exhibit 2

Exhibit 2

Exhibit A

Exhibit 2

Exhibit 2

Exhibit 2

Exhibit 2

Exhibit 2

Exhibit Ex. 2 - Defendants Responses to Plaintiffs Interrogatories

Exhibit Ex. 2 - Defendants Responses to Plaintiffs Interrogatories

MOTION by Plaintiff Hallmark Licensing, LLC for leave to file under Seal

Exhibit 3

Exhibit 3

Exhibit 3

Exhibit 3

CIVIL Cover Sheet

Exhibit 4

Exhibit 4

Exhibit 4

Exhibit 4

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

Exhibit 5

Exhibit 5

Exhibit 5

Exhibit 5

Notice of Claims Involving Trademarks by Hallmark Licensing, LLC

Exhibit 6

Exhibit 6

Exhibit 6

Exhibit 6

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

Exhibit 7

Exhibit 7

Exhibit 7

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Amy Crout Ziegler

Exhibit 8

Exhibit 8

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Rachel S Miller

Exhibit 9

Exhibit 9

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Madeline Halgren

Exhibit 10

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2). (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.)

NEW PARTIES: Shenzhen Yagelong Technology Co., Ltd., Shenzhen Yaxinlong Technology Co., Ltd., Suzhou Qianmengshihua Technology Co., Ltd., DYW TOYS, KAWAJP, WENNISTORE, baofu005, beneony, candy_bean, dhpetbf, dhpetbg, dhpetbh, dhpetbi, dhshoesmd, flowery888, lanmmg, meck, mr_wardrobe011, olylin1, qiaomaidou05, the_medallion, ua_hartford, ua_laguna, ua_niguel, wenxin_pavilion1, xiaoyanyes, ojioahn2, AMZXZ, Block Warriors, CHEN LU FEI, City Night, Comfor Living, CSDADJMB, Dapper Dudes Tees, DAYONEE, Divine Lotins, DQWERCHA, DreamBit, Easy lane Atwo, FUSHENGshangmao, GchengchengA, Hzx new, jiechengjiafang, jieshengchuanqi, JING GOGOB, Love In Life, Luckiness F, Nakewan, NiceCoo, OK MA, OKC JLY, QIHUANWU, Qster, quanjianhaotanF, SFDGHH, shengliangxiaodian, shuchangfuzhuang, Spell beautifulEE, SSLYE, TshirtKing, xubaojiafang, ydtyyshop, yuedouxiaodian, ziduFirst, ziduKing, ziduYyds, Zz fun stickers, BigLeopard Shop, DengChengLin, GIERIDUC, HETUIWLO, jiaomeng, KiRimity, PENGHE Co.Ltd, SENYERGIANT, Yunyao and ZAOTAI Co.Ltd added to case caption. (Text entry; no document attached.)

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Hallmark Licensing, LLC to Greer, Burns & Crain, Ltd. 200 West Madison Suite 2100 Chicago, IL 60606 via certified mail # 9589 0710 5270 0579 7845 06. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

Exhibit 11

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

Exhibit 12

MAILED copyright report to Registrar, Washington DC

Exhibit 13

MOTION by Plaintiff Hallmark Licensing, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

Exhibit 14

MEMORANDUM by Hallmark Licensing, LLC in support of motion for temporary restraining order[14]

Exhibit 15

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

DECLARATION of Stacey Howe regarding memorandum in support of motion[15]

SEALED EXHIBIT by Plaintiff Hallmark Licensing, LLC Exhibit 3 - Parts 1-2 regarding declaration[17]

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

MEMORANDUM by Hallmark Licensing, LLC in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[14], motion for miscellaneous relief[19] before Honorable Elaine E. Bucklo on 3/12/2025 at 09:45 AM.

ATTORNEY Appearance for Plaintiff Hallmark Licensing, LLC by Jennifer Van Nacht

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal [3]; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [14]; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [19] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 3/31/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 3/24/2025. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 5/1/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 4/24/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 3/17/2025. Mailed notice.

Registry Deposit Information Form by Hallmark Licensing, LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Hallmark Licensing, LLC

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

INJUNCTION BOND in the amount of $ 10,000 posted by Hallmark Licensing, LLC (Document not scanned)

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

MEMORANDUM by Hallmark Licensing, LLC in support of extension of time[30]

DECLARATION of Jennifer V. Nacht regarding memorandum in support of motion[31]

NOTICE of Motion by Jennifer Van Nacht for presentment of extension of time[30] before Honorable Elaine E. Bucklo on 3/27/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the Temporary Restraining Order [30] is granted to 4/14/2025. Mailed notice.

MOTION by Plaintiff Hallmark Licensing, LLC for preliminary injunction

MEMORANDUM by Hallmark Licensing, LLC in support of motion for preliminary injunction[35]

DECLARATION of Jennifer V. Nacht regarding memorandum in support of motion[36]

NOTICE of Motion by Jennifer Van Nacht for presentment of motion for preliminary injunction[35] before Honorable Elaine E. Bucklo on 4/3/2025 at 09:45 AM.

SUMMONS Returned Executed by Hallmark Licensing, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/28/2025, answer due 4/18/2025.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction 35 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Stacey Howe 18, and the TRO 25. Mailed notice.

PRELIMINARY INJUNCTION ORDER signed by the Honorable Elaine E. Bucklo on 4/9/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain defendants

ATTORNEY Appearance for Defendants PENGHE Co.Ltd, ZAOTAI Co.Ltd by He Cheng

ANSWER to Complaint by PENGHE Co.Ltd

ANSWER to Complaint by ZAOTAI Co.Ltd

MOTION by Plaintiff Hallmark Licensing, LLC to approve consent judgment as to Certain Defendants

NOTICE of Motion by Jennifer Van Nacht for presentment of motion to approve consent judgment[47] before Honorable Elaine E. Bucklo on 4/30/2025 at 09:45 AM.

NOTICE of Voluntary Dismissal by Hallmark Licensing, LLC as to certain Defendants

MOTION by Plaintiff Hallmark Licensing, LLC for entry of default, MOTION by Plaintiff Hallmark Licensing, LLC for default judgment as to all Defendants

MEMORANDUM by Hallmark Licensing, LLC in support of motion for entry of default, motion for default judgment[50]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[51]

NOTICE of Motion by Jennifer Van Nacht for presentment of motion for entry of default, motion for default judgment[50] before Honorable Elaine E. Bucklo on 4/30/2025 at 09:45 AM.

STATUS Report per [24] by Hallmark Licensing, LLC

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff's agreed motion for entry of a consent judgment as to Defendants GIERIDUC (Def. No. 70) and KIRIMITY (Def No. 73)[47] is granted. Enter Consent Judgment. Plaintiff's motion for entry of default and default judgment against the defendants identified on Schedule A [50] is granted. Enter Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to plaintiff or its counsel Greer Burns & Crain Ltd. Status hearing is reset for 6/17/2025 at 9:45 a.m. as to remaining non-dismissed Defendants PENGHE Co.Ltd (Def. No. 74) and ZAOTAI Co.Ltd (Def. No. 77) (to track the case only, no appearance is required). The parties shall file a joint written status report by 6/10/2025. The court will enter a scheduling order in response to the status report. Mailed notice.

CONSENT JUDGMENT signed by the Honorable Elaine E. Bucklo on 4/28/2025. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 4/28/2025. Mailed notice.

STATUS Report per 55 (Joint) by Hallmark Licensing, LLC

MINUTE entry before the Honorable Elaine E. Bucklo: The Court adopts the report of parties planning meeting. Dispositive motions with supporting memoranda due by 7/9/2025. Responses due by 7/30/2025. Replies due by 8/13/2025. Ruling set for 9/12/2025. The court will issue a ruling by mail. Mailed notice

MOTION by Plaintiff Hallmark Licensing, LLC for summary judgment and an Award of Statutory Damages

MEMORANDUM by Hallmark Licensing, LLC in support of motion for summary judgment[60]

RULE 56.1(a)(2) Statement by Hallmark Licensing, LLC regarding motion for summary judgment[60]

DECLARATION of Stacey Howe regarding Rule 56 statement[62]

DECLARATION of Jennifer V. Nacht regarding Rule 56 statement[62]

MOTION by Plaintiff Hallmark Licensing, LLC for summary judgment and an Award of Statutory Damages

MEMORANDUM by Hallmark Licensing, LLC in support of motion for summary judgment[65]

RULE 56.1(a)(2) Statement by Hallmark Licensing, LLC regarding motion for summary judgment[65]

DECLARATION of Stacey Howe regarding Rule 56 statement[67]

DECLARATION of Jennifer V. Nacht regarding Rule 56 statement[67]

RESPONSE by Defendant ZAOTAI Co.Ltd to Rule 56 statement[62]

DECLARATION of He Cheng regarding Response[70]

RESPONSE by ZAOTAI Co.Ltd to MOTION by Plaintiff Hallmark Licensing, LLC for summary judgment and an Award of Statutory Damages [60]

RESPONSE by Defendant PENGHE Co.Ltd to Rule 56 statement[67]

DECLARATION regarding Response[73]

RESPONSE by PENGHE Co.Ltd to MOTION by Plaintiff Hallmark Licensing, LLC for summary judgment and an Award of Statutory Damages [65]

REPLY by Plaintiff Hallmark Licensing, LLC in Support of Plaintiff's Motion for Summary Judgment [60]

REPLY by Plaintiff Hallmark Licensing, LLC in Support of Plaintiff's Motion for Summary Judgment [65]