2025-cv-02282

COMPLAINT filed by Triumph International, LLC; Filing fee $ 405, receipt number AILNDC-23163538.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Triumph International, LLC Schedule A regarding complaint 1

MOTION by Plaintiff Triumph International, LLC for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Triumph International, LLC

Notice of Claims Involving Trademarks by Triumph International, LLC

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Alexander Whang

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Young B. Kim. 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: Aungagen, ChssyuweT, CiviLight US Direct, Cranesa, Dizller USA, Faddy-Rox, GracePosters, Guangzhou yi die shangmao shanghang geren duzi, guangzhouyezhiyunshangmaoshanghanggerenduzi, Hubinbinbin, Jamesiller, Judioung, lian hao dian zi shang wu, liuhuidebeimeidian, Mary Towns, MJB2C, NM-Fashion, QAWAICCHE, ROADIES MART, S Wangfangcai, SAEEMANI, veratwo, Vonglostore, wangjunfeng A, Zhangzhengzheng, 93stores, 9ninecloth, All Day Tee, Digitalprintcustom.com, elambotee, EMMAXTEE, Evofox, FanaticsLand, Ferolos, Gear Fandom, Growkoc, HAPPYINKTEE, Hoodiego, Ink In Action, Inspirdg, Kessol, Mechsunshine, MJ Market, Odinta, Q-Finder, Rebsuke, StormMerch, tagowear, The Age of Miracles, TrendyAloha, Zenassan Store, Altaic Tiger, Artisan Craftworks of shop, BAOMA ART, BKBF, Blossom Belle, Bought It grocer ease, CjwTshirt, CXW SHOP, Dandys wardrobe, Diy A Boutique, e couple, E SHINE PLUS local, ETERNAL HOPE, Fairus, Femmes, FT IRON SHEET PAINING, GlobeStyleMen, HXArt, JHClothing, Jiuwu I, Jiuwu Z, Kaycees, MDLClothing, Mens Black Tee Shirts, MISEFF clothing, MODERN GENTS, MSQ four, NewDiy Zone, onbuy, Pink Zebra, PrintElement, Serendys, sheshowbuy, SIGN LLL, SIGN SSSI, SINK decoration, Spring Begins, Timeless Trends, WG Fashion Mens Wardrobe, Xiumei A Get Rich, Xiyun Art Wall Decor, Yi Lin Metal sign shop, Youhuike, ZFGClothing, Zhen Feng Decor, D&D Everything, Elegance Echo, gfddgdfgdfghf, guangzhoumaidashangmaoyouxiangongsi, Happy Cloud Farm, THANH CONG PRINT LTD, Xiujin and yahanmoshangmao added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Triumph International, LLC to Attorney Martin Francis Trainer (TME Law, P.C.) 10 S. Riverside Plaza, Suite 875 Chicago, IL 60606 certified mail # 9589 0710 5270 0579 7830 42

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

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 March 12, 2025, the Court may dismiss this matter for failure to prosecute. Mailed notice.

EXHIBIT by Plaintiff Triumph International, LLC Schedule of Defendants

Exhibit 1

Exhibit 1-1

(Exhibit 1-2)

MOTION by Plaintiff Triumph International, LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief 14

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 15

(Exhibit 1)

EXHIBIT by Plaintiff Triumph International, LLC Exhibit 2, Parts 1-6 regarding declaration 16

Exhibit 2, Part 1

Exhibit 2, Part 2

Exhibit 2, Part 3

Exhibit 2, Part 4

Exhibit 2, Part 5

(Exhibit 2, Part 6)

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

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief 18

Declaration of Martin F. Trainor

(Exhibit 1)

ORDER written by the Honorable Lindsay C. Jenkins on 3/13/2025. Mailed notice.

SEALED TRO Signed by the Honorable Lindsay C. Jenkins on 3/13/2025. Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Triumph International, LLC

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

MOTION by Plaintiff Triumph International, LLC to Extend the Temporary Restraining Order

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief 25

(Declaration of Martin F. Trainor)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to extend the TRO 25 is granted. The TRO is extended to April 10, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

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

SUMMONS Returned Executed by Triumph International, LLC as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 4/7/2025, answer due 4/28/2025.

Declaration of Sydney Fenton

(Exhibit A)

MOTION by Plaintiff Triumph International, LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Triumph International, LLC in support of motion for preliminary injunction 32

Declaration of Martin F. Trainor

(Exhibit 1)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 32 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 April 11, 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 Triumph International, LLC

(Exhibit A)

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 32 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 36 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 TME Law, P.C., 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 ORDER Signed by the Honorable Lindsay C. Jenkins on 4/14/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: By May 2, 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 Triumph International, LLC as to certain Defendants

STATUS Report by Triumph International, LLC

(Exhibit A)

MOTION by Plaintiff Triumph International, LLC for extension of time for entry of default and default judgment

MINUTE entry before the Honorable Lindsay C. Jenkins: : Plaintiff's motion for an extension of time 44 is granted. Any motion for default judgment must be filed by June 6, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

MOTION by Plaintiff Triumph International, LLC for entry of default, MOTION by Plaintiff Triumph International, LLC for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Triumph International, LLC in support of motion for entry of default, motion for default judgment 50

(Exhibit 1)

DECLARATION of Martin F. Trainor regarding memorandum in support of motion 51

(Exhibit 1)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 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 June 16, 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 June 12, 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 Sydney Paige Fenton on behalf of Triumph International, LLC

(Exhibit A)

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [50] 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. The Clerk is directed to return the surety bond posted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Lindsay C. Jenkins on 6/17/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain Defendant

EMAILED Trademark report with certified copy of minute order dated 06/20/25 to Patent Trademark Office, Alexandria VA