2025-cv-02525

2025-cv-02525 The Liverpool Football Club and Athletic Grounds Limited v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :3/11/2025
Court :Northen District of Illinois
Law FirmGBC

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Date

Document

1

March 11, 2025

COMPLAINT filed by The Liverpool Football Club and Athletic Grounds Limited; Filing fee $ 405, receipt number AILNDC-23190993.

Exhibit 1

2

March 11, 2025

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Schedule A regarding complaint[1]

3

March 11, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for leave to file under Seal

4

March 11, 2025

CIVIL Cover Sheet

5

March 11, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Liverpool Football Club and Athletic Grounds Limited

6

March 11, 2025

Notice of Claims Involving Trademarks by The Liverpool Football Club and Athletic Grounds Limited

7

March 11, 2025

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Justin R. Gaudio

8

March 11, 2025

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Amy Crout Ziegler

9

March 11, 2025

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Trevor Christian Talhami

10

March 11, 2025

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Jennifer Van Nacht

March 11, 2025

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Maria Valdez. 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: Shenzhen Shine Sky International Electronic Co., Ltd., Wuhan Best Industrial Trading Co., Ltd., Xiamen Axfu Electronic Tech Co., Ltd., Yiwu Qianming Jewelry Co., Ltd., A28GE8GMR7VDA0, A2PKHYA5PGRURC, A2QQ772RAVKT4F, A2WV105O90AA4E, duytungnadon, GangXueXueGang, guangzhouhuankeshangmao, KT STOREDN4, Leann Poster, lixinkehenanhenawenhuachuan, mintoudianzi, shanxihongruiquanjianzhugongchengyouxiangongsi, VA StoreKIX, Yangguangquan, yongjishixinchengwuyeguanliyouxiangongsi, zhangjintinggongyipindian, ZHM4455, JIT Painting, Brother Teddy Co.,Ltd, Cmuxi Clothing Co.,LTD, CuYou Clothing Co.,LTD, Dongguanshikaituozhe, GZZHZNZB, junchuodianzi, LIANXUN, LJB-YC, lumengdianzishangwu, putianlichengquxinkongmaoyiyouxiangongsi, Sien Co.,LTD, VIP ONE, Wami Co.,LTD and XJYLWHCM store added to case caption.

11

March 11, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

12

March 12, 2025

MAILED Trademark report to Patent Trademark Office, Alexandria VA

13

March 12, 2025

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

14

March 13, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

15

March 13, 2025

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for temporary restraining order[14]

16

March 13, 2025

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

17

March 13, 2025

DECLARATION of Paul Dicken regarding memorandum in support of motion[15]

Exhibit 1

18

March 13, 2025

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Exhibit 2 regarding declaration[17]

19

March 13, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

20

March 13, 2025

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for miscellaneous relief[19]

21

March 13, 2025

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

22

March 13, 2025

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

23

March 13, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [19] is granted. Mailed notice.

24

March 13, 2025

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 3/13/2025. Mailed notice.

25

March 13, 2025

Registry Deposit Information Form by The Liverpool Football Club and Athletic Grounds Limited

26

March 13, 2025

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff The Liverpool Football Club and Athletic Grounds Limited

27

March 14, 2025

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

28

March 17, 2025

SURETY BOND in the amount of $9,000 posted by The Liverpool Football Club and Athletic Grounds Limited (Document not scanned)

29

March 24, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for extension of time of Temporary Restraining Order

30

March 24, 2025

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of extension of time[29]

31

March 24, 2025

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[30]

32

March 24, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [29] is granted. The Temporary Restraining Order entered on 3/13/2025 [24] is extended by a period of fourteen (14) days until 4/10/2025. Mailed notice.

33

March 27, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction

(Exhibit A)

34

March 27, 2025

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for preliminary injunction 33

35

March 27, 2025

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 34

36

March 27, 2025

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 33 is set for 4/3/2025 at 9:45 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

37

March 27, 2025

SUMMONS Returned Executed by The Liverpool Football Club and Athletic Grounds Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/27/2025, answer due 4/17/2025.

Declaration of Jennifer V. Nacht

(Exhibit A)

38

April 3, 2025

Entered in error. Modified on 4/3/2025.

39

April 3, 2025

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 4/3/2025. Mailed notice. (Main Document 39 replaced on 4/3/2025).

40

April 3, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Minute entry 38 is stricken and corrected as follows. Motion hearing held on 4/3/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 33 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibits to the Declaration of Paul Dicken 18, and the TRO 24 are. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 4/30/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

41

April 21, 2025

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for entry of default, MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for default judgment as to all Defendants

(Exhibit A)

42

April 21, 2025

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for entry of default, motion for default judgment, 41

Exhibit 1

(Exhibit 2)

43

April 21, 2025

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

(Exhibit 1)

44

April 21, 2025

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 4/30/2025 at 9:15 a.m. is converted to a telephone hearing on the motion for entry of default and for default judgment 41. Mailed notice.

45

April 29, 2025

MINUTE entry before the Honorable Thomas M. Durkin: The telephone hearing on the motion for entry of default and for default judgment [41] set for 4/30/2025 is reset for 5/1/2025 at 9:15 a.m. Mailed notice.

46

May 1, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/1/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and for default judgment 41 is granted. Enter order. Civil case terminated. Mailed notice.

47

May 1, 2025

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 5/1/2025. Mailed notice.

48

May 1, 2025

MAILED Trademark report with certified copy of minute order dated 5/1/2025 to Patent Trademark Office, Alexandria VA

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