2025-cv-02278

COMPLAINT filed by Peixian JiYi Cat Trading Co. Ltd.; Filing fee $ 405, receipt number AILNDC-23163085.

Exhibit Exh 1 - An Infringing Product

Exhibit Exh 2 - US Pat D1038258

Exhibit Exh 3 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 4 - Alibaba, Amazon, and Counterfeiting in the Age of the Internet

(Exhibit Exh. 5 - Combating Trafficking in Counterfeit and Pirated Goods)

SEALED DOCUMENT by Plaintiff Peixian JiYi Cat Trading Co. Ltd. Schedule A to Complaint

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Peixian JiYi Cat Trading Co. Ltd. by Konrad Val Sherinian

ATTORNEY Appearance for Plaintiff Peixian JiYi Cat Trading Co. Ltd. by Depeng Bi

MAILED Patent report to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff Peixian JiYi Cat Trading Co. Ltd. for temporary restraining order

MEMORANDUM by Peixian JiYi Cat Trading Co. Ltd. in support of motion for temporary restraining order 7

DECLARATION of Konrad Sherinian regarding motion for temporary restraining order 7

Exhibit Exh. 1 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 2 - Hague Convention

Exhibit Exh. 3 - Civil Procedure Law of the People's Republic of China

(Exhibit Exh. 4 - Binder of Unreported Cases)

DECLARATION of Ran Wei regarding motion for temporary restraining order 7

SEALED DOCUMENT by Plaintiff Peixian JiYi Cat Trading Co. Ltd. Exh 1 to Dec of Ran Wei - Evidence of Infringement

MOTION by Plaintiff Peixian JiYi Cat Trading Co. Ltd. to seal document sealed document 11, sealed document 2

MOTION by Plaintiff Peixian JiYi Cat Trading Co. Ltd. for leave to file excess pages

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Peixian JiYi Cat Trading Co. Ltd.

NOTICE by Peixian JiYi Cat Trading Co. Ltd. re complaint, 1 Notice of Claims Involving Patents

MINUTE entry before the Honorable John F. Kness: On the Court's initiative, all pending motions are held in abeyance, and the case is stayed pending further order. This stay, which the Court is entering in other so-called "Schedule A" cases on its docket where requests for temporary restraining orders remain pending, is intended to permit the Court the opportunity to reassess its previous approach in Schedule A litigation involving Lanham Act, Copyright Act, and Patent Act claims typically brought on an ex parte basis against various online merchants. This reassessment will consider, among other things, whether: (1) ex parte proceedings are appropriate in these types of cases; (2) the routine sealing of parts or all of the docket is appropriate; (3) the routine granting of temporary restraining orders on an ex parte basis is a sound exercise of judicial discretion; (4) the routine granting of prejudgment asset restraints is a sound exercise of judicial discretion; and (5) the mass joinder of defendants is appropriate under the circumstances typically present in Schedule A cases. Plaintiff remains free, of course, to dismiss this action voluntarily if they wish to pursue their claims in another District, but no supplemental briefing on the pending motions may be filed absent advance leave of Court. Mailed notice.

RESPONSE by Defendant Shenzhen Langyue Technology Co. to the temporary restraining order. (Exhibits) (Received via pro se email on 4/23/25.)

MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for an ex parte temporary restraining order, prejudgment asset restraint, and expedited discovery (Dkt. 7) is denied substantially for the reasons provided in the opinion denying similar requested relief in Eicher Motors Limited v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto F. Supp. 3d, 2025 WL 2299593 (N.D. Ill. Aug. 8, 2025). Plaintiff's motion to seal (Dkt. 12) is granted subject to later reconsideration; the documents provisionally filed under seal may remain under seal for the time being. The request for alternative service (Dkt. 7, 8) and motion for leave to file excess pages (Dkt. 13) are granted. An in-person status hearing is set for 8/26/2025 at 11:30 a.m.; lead counsel must appear in person at the hearing, which will be stricken if Plaintiff elects to dismiss this action voluntarily. Plaintiff is invited to file a motion seeking certification of an interlocutory appeal of this ruling. Mailed notice.