2025-cv-02388

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-23174799.

(Exhibit 1)

EXHIBIT by Plaintiff Nike, Inc. Schedule A regarding complaint 1 Modified on 5/22/2025.

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

CIVIL Cover Sheet

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

Notice of Claims Involving Trademarks by Nike, Inc.

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

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

ATTORNEY Appearance for Plaintiff Nike, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Nike, Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable M. David Weisman. 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: HHOUOKAN, Hi Shopping Mall local, Hi Summer A, Hiphop Dudes Funhouse, HONGHUORIZI, Hope Xilai, huangfuzhuang, Infinite growth, Jack DepartmenR local, JHYGYTK, JIANGXIWEILANG, Jiexiner, JinTX fiveCH, Jiuwu X, JOHHN, Jovial Attire, KSDWZDWST, LoveShirts, LSHTF, Luck starts, LUCKYMii, LUXE LAYERS TEE, Male Lion, Man fashion clothing shop, MARCONG, MargoChoehai, Me Time phone case, Meeyius Goldcast, Men customization, Mens Fashion Studio, Mens home for leisure, MMfourShop, Mr Linnnnnn, Mr Wardrobe f, MR YMM, MTH Apparel, Multifunctional Tshirt, MyZhuo, NeeMooPoint, Nerinvi QB, Niche Nova, NUUOKWXH, OBM Cotton clothes, OneGlob, Over the hat, Personalized Thread, Phoenix OB, Prima Toby, PrintLovers, QJSDEEE, QS Customized and quanjianhaotanG added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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

MEMORANDUM by Nike, Inc. in support of motion for temporary restraining order 13

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

DECLARATION of Joe Pallett regarding memorandum in support of motion 14

(Exhibit 1)

EXHIBIT by Plaintiff Nike, Inc. Exhibit 2 - Parts 1-2 regarding declaration 16 Modified on 5/22/2025.

Exhibit 2-1

(Exhibit 2-2)

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

MEMORANDUM by Nike, Inc. in support of motion for miscellaneous relief 18

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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 4/3/2025 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Plaintiff Nike, Inc. by Trevor Christian Talhami

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 4/3/2025. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A regarding complaint 2, and (2) Exhibit 2 - Parts 1-2 17. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 8:00 a.m. on 4/7/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 4/21/2025 at 12:30 PM. [Note Date Change]. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 4/7/2025. Mailed notice Modified on 5/22/2025.

Registry Deposit Information Form by Nike, Inc.

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

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

MOTION by Plaintiff Nike, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction 29

(Declaration of Marcella D. Slay)

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/16/2025, answer due 5/7/2025.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction 29 will be heard at the telephonic hearing set for 4/21/2025 at 12:30 PM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing set for 4/21/2025 is stricken and reset for 4/21/2025 at 3:00 PM. [TIME CHANGE ONLY]. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 4/21/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 29 is granted. Enter Preliminary Injunction Order. Plaintiff's anticipated motion for default and default judgment shall include a spreadsheet that identifies up-to-date information on the amounts that are being restrained for each of the remaining defendants. The Clerk's Office is directed to unseal: (1) Schedule A regarding complaint 2, (2) Exhibit 2 - Parts 1-2 17, and (3) the sealed temporary restraining order 24. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 5/22/2025 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 4/21/2025. Mailed notice

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

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

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

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

MINUTE entry before the Honorable Andrea R. Wood. Telephone status held 5/22/25 and continued to 6/24/25 at 9:30 a.m. Only plaintiff's counsel appeared. Any motion for default and default judgment to be filed seven (7) days prior to the next status in order to be heard at that status hearing. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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

NOTICE of Voluntary Dismissal by Nike, Inc. as to a Certain Defendant

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

(Exhibit A)

MEMORANDUM by Nike, Inc. in support of motion for entry of default, motion for default judgment 43

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 44

Exhibit 1

(Exhibit 2)

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

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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment as to all remaining defendants 43 will be heard at the telephonic hearing set for 6/24/2025 at 9:30 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion and status hearing held on 6/24/2025. No Defendants appeared. Plaintiff's motion for entry of default and default judgment as to all remaining Defendants [43] is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice. (jn,)

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 6/30/2025. Mailed notice. (jn,)

MAILED trademark report with certified copy of minute order dated 6/24/25 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding Default Judgment, order 51 in the amount of $500,000 as to certain defendant

NOTICE of withdrawal of bond [28] by John Summerfield