2025-cv-02721

2025-cv-02721 Crye Precision LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

Date :3/14/2025
BrandCrye Precision
Court :Northen District of Illinois
Law FirmGBC

#

Date

Document

1

March 14, 2025

COMPLAINT filed by Crye Precision LLC; Filing fee $ 405, receipt number AILNDC-23212208.

Exhibit 1

((List of Trademarks, Ex. 1))

((List of Copyrights Ex. 2))

Exhibit 1

Exhibit 3-1

(Exhibit A)

(Declaration of Kahlia R. Halpern)

Declaration of Madeline B. Halgren

Declaration Declaration of Zheng

(Exhibit 1)

(Exhibit)

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit 1

(Exhibit A)

2

March 14, 2025

SEALED EXHIBIT by Plaintiff Crye Precision LLC Schedule A regarding complaint 1

(Exhibit 2)

(Exhibit 2)

(Exhibit 3-2)

(Exhibit A)

Declaration Attorney's Declaration

Exhibit 2

Exhibit 2

Exhibit 2

3

March 14, 2025

MOTION by Plaintiff Crye Precision LLC for leave to file under seal

Exhibit 1

Exhibit A

4

March 14, 2025

CIVIL Cover Sheet

Exhibit 2

5

March 14, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Crye Precision LLC

Exhibit 3

6

March 14, 2025

Notice of Claims Involving Trademarks by Crye Precision LLC

Exhibit 4

7

March 14, 2025

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Justin R. Gaudio

Exhibit 5

8

March 14, 2025

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Amy Crout Ziegler

Exhibit 6

9

March 14, 2025

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Kahlia Roe Halpern

(Exhibit 7)

10

March 14, 2025

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Madeline Halgren

March 17, 2025

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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: GUI-L, HJTW, hunanhanyujiankangkejiyouxiangongsi, IFNT, JOYASUS, Land-Warrior, LASVENIS Outdoor Products, sczhengyishangmao, VOTAGOO Gear, WOSONG, xingchenweishangmaoyouxiangongsi, zhongchenghaowushangmaoyouxiangongsi, Aiyaoyao, fair233 shop, iuep1403, ww2collectible2021, falunfannuo, HappyMart, IOUPQOETRQT and ROCOTACTICAL added to case caption. (Text entry; no document attached.)

11

March 17, 2025

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

12

March 17, 2025

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

13

March 17, 2025

MAILED Copyright report to Registrar, Washington DC.

14

March 18, 2025

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

15

March 18, 2025

MEMORANDUM by Crye Precision LLC in support of motion for temporary restraining order 14

16

March 18, 2025

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

17

March 18, 2025

DECLARATION of Jonathan E. Antone regarding memorandum in support of motion 15

18

March 18, 2025

SEALED EXHIBIT by Plaintiff Crye Precision LLC Exhibit 3 Parts 1-2 regarding declaration 17

19

March 18, 2025

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

20

March 18, 2025

MEMORANDUM by Crye Precision LLC in support of motion for miscellaneous relief 19

21

March 18, 2025

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

22

April 2, 2025

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 14 is granted. Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 19 are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

23

April 2, 2025

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 4/2/2025.

25

April 2, 2025

Registry Deposit Information Form by Crye Precision LLC

26

April 2, 2025

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

27

April 8, 2025

SURETY BOND in the amount of $ 85,000.00 posted by Crye Precision LLC. (Document not scanned)

28

April 11, 2025

MOTION by Plaintiff Crye Precision LLC for preliminary injunction

29

April 11, 2025

MEMORANDUM by Crye Precision LLC in support of motion for preliminary injunction 28

30

April 11, 2025

SUMMONS Returned Executed by Crye Precision LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/11/2025, answer due 5/2/2025.

31

April 15, 2025

ATTORNEY Appearance for Defendants Be Dreamer, Univers Land, YINGMENG-US by Lance Y. Liu

32

April 16, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

33

April 17, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

34

April 21, 2025

ATTORNEY Appearance for Defendant LD FREE by Ruixin Lu

35

April 24, 2025

ATTORNEY Appearance for Defendant Panda Outdoor Explorer by Longhao Wang

36

April 24, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

37

April 25, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

38

April 28, 2025

ATTORNEY Appearance for Defendant ZRong-US by Zhongyi Huang

39

April 28, 2025

RESPONSE by ZRong-USin Opposition to MOTION by Plaintiff Crye Precision LLC for preliminary injunction 28

40

April 29, 2025

ATTORNEY Appearance for Defendants Refire Gear, TREKEK by Longhao Wang

41

April 29, 2025

MINUTE entry before the Honorable Mary M. Rowland: Response to motion for preliminary injunction 28 due 5/16/25. Status report due 5/30/25. Mailed notice.

42

April 30, 2025

MOTION by Defendant ZRong-US for extension of time to file answer regarding complaint 1

43

May 1, 2025

MINUTE entry before the Honorable Mary M. Rowland: Defendant's motion for extension to answer 42 is granted. Answer due 5/12/25. Mailed notice.

44

May 1, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

45

May 2, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Refire Gear

46

May 2, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TREKEK

47

May 2, 2025

ANSWER to Complaint by Refire Gear

48

May 2, 2025

ANSWER to Complaint by TREKEK

49

May 2, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Panda Outdoor Explorer

50

May 2, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

51

May 2, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Panda Outdoor Explorer (corrected)

52

May 2, 2025

ANSWER to Complaint by Panda Outdoor Explorer

53

May 2, 2025

ATTORNEY Appearance for Defendant COSCOOA by Yong Chen

54

May 2, 2025

MOTION by Defendant COSCOOA for extension of time to file answer regarding complaint 1, CONSENTED

55

May 5, 2025

MINUTE entry before the Honorable Mary M. Rowland: Defendant's motion for extension of time to answer 54 is granted. Defendant COSCOOA granted until 5/22/25 to answer. Mailed notice.

56

May 5, 2025

ATTORNEY Appearance for Defendant TIANKU Co.Ltd by He Cheng

57

May 5, 2025

MOTION by Defendant TIANKU Co.Ltd for extension of time to file answer regarding complaint 1

58

May 6, 2025

MINUTE entry before the Honorable Mary M. Rowland: MOTION by Defendant TIANKU Co. Ltd for extension of time to file answer 57 is granted. Answer due 6/2/25. Mailed notice.

59

May 8, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

60

May 12, 2025

ATTORNEY Appearance for Defendant Lytharvest by Timothy Tiewei Wang

61

May 12, 2025

MOTION by Defendant Lytharvest for extension of time to file answer regarding complaint 1 Unopposed

62

May 12, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

63

May 12, 2025

ANSWER to Complaint by Be Dreamer, Univers Land, YINGMENG-US

64

May 13, 2025

MINUTE entry before the Honorable Mary M. Rowland: Defendant Lytharvest motion for extension of time to file answer 61 is granted. Answer is due 5/23/25. Mailed notice.

65

May 15, 2025

MOTION by Plaintiff Crye Precision LLC to strike answer to complaint 63

66

May 15, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

67

May 15, 2025

RESPONSE by Be Dreamer, Univers Land, YINGMENG-USin Opposition to MOTION by Plaintiff Crye Precision LLC to strike answer to complaint 63 65

68

May 16, 2025

STIPULATION of Dismissal as to a Certain Defendant (Joint)

69

May 16, 2025

STIPULATION of Dismissal as to a Certain Defendant (Joint)

70

May 16, 2025

STIPULATION of Dismissal as to a Certain Defendant (Joint)

71

May 19, 2025

ATTORNEY Appearance for Defendants ace-arms, krydex-tactical, NOX OUTDOOR GEAR by Christopher Paul Keleher

72

May 19, 2025

MOTION by Defendants NOX OUTDOOR GEAR, ace-arms, krydex-tactical for extension of time to file answer regarding complaint 1 (UNOPPOSED)

73

May 20, 2025

MINUTE entry before the Honorable Mary M. Rowland: Defendants NOX OUTDOOR GEAR, ace-arms, krydex-tactical's Motion for extension of time [72] to file answer is granted. Response to the complaint from these defendants due 6/9/25. Mailed notice.

74

May 21, 2025

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion to strike the answer by Be Dreamer, Univers Land, YINGMENG-US [65] is denied. Mailed notice.

75

May 22, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

76

May 29, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

77

May 30, 2025

STATUS Report Pursuant to [41] by Crye Precision LLC

78

June 2, 2025

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [41]. No remaining defendant has filed an opposition to the motion for preliminary injunction [28]. The motion for preliminary injunction is granted and entered. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

79

June 2, 2025

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 6/2/2025. Mailed notice.

80

June 2, 2025

ANSWER to Complaint by TIANKU Co.Ltd

81

June 3, 2025

STIPULATION of Dismissal as to Certain Defendants (Joint)

82

June 5, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

83

June 12, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain Defendants

84

June 12, 2025

MOTION by Plaintiff Crye Precision LLC for entry of default, MOTION by Plaintiff Crye Precision LLC for default judgment as to all Defendants

85

June 12, 2025

MEMORANDUM by Crye Precision LLC in support of motion for entry of default, motion for default judgment[84]

86

June 12, 2025

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[85]

87

June 13, 2025

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion for entry of default and default judgment as to all defendants [84] shall be briefed as follows: Plaintiff's response is due by 6/27/2025 and Defendants' reply is due by 7/9/2025. Mailed notice

88

June 18, 2025

MINUTE entry before the Honorable Mary M. Rowland: The Court corrects the order setting briefing that was entered on 6/13/25 [87] as follows: Plaintiff's motion for entry of default and default judgment as to all defendants [84] shall be briefed as follows: Defendants' response is due by 6/27/2025 and Plaintiff's reply is due by 7/9/2025. Status report due 7/15/25. Mailed notice.

89

June 19, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

90

June 19, 2025

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Andrew Daniel Burnham

91

June 23, 2025

DECLARATION of Yinjuan Liang in support of motion to set aside default. (Received via pro se online portal on 6/23/25.)

92

June 23, 2025

ANSWER to Complaint by Defendant JOYASUS. (Received via pro se online portal on 6/23/25.)

93

June 23, 2025

MOTION to set aside default for insufficient service of process by Defendant JOYASUS. (Received via pro se online portal on 6/23/25.)

94

June 25, 2025

MOTION by Plaintiff Crye Precision LLC to strike MOTION by Defendant JOYASUS [93], declaration[91], answer to complaint[92]

95

June 25, 2025

DEFENDANT JOYASUS'S MOTION TO SET ASIDE DEFAULT FOR INSUFFICIENT SERVICE OF PROCESS.

96

June 25, 2025

ANSWER to Complaint by Defendant JOYASUS. (Received via pro se online portal on 6/25/25.)

97

June 25, 2025

DECLARATION of Yinjuan Liang regarding DEFENDANT JOYASUS'S MOTION TO SET ASIDE DEFAULT FOR INSUFFICIENT SERVICE OF PROCESS. [95] (Received via pro se online portal on 6/25/25.)

98

June 27, 2025

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion 94 to strike JOYAS' Motion to set aside the default 93 and Answer 92 is granted. First there has not been a default entered. Second, JOYAS is not represented by counsel. As a corporate entity, even one with only one member, it must have counsel. The Answer 92 is stricken and JOYAS' motion 93 is denied. Plaintiff's motion 94 is granted. This reasoning applies to JOYAS' motion regarding insufficient service 95. That motion is denied because JOYAS is not properly represented by counsel. Mailed notice.

99

July 2, 2025

MINUTE entry before the Honorable Mary M. Rowland: The court failed to strike Answer 96 from the docket in the 6/27/25 minute order 98. The Answer to Complaint by Defendant JOYASUS 96 is also stricken. Mailed notice.

100

July 3, 2025

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

101

July 15, 2025

STATUS Report Pursuant to 88 by Crye Precision LLC

102

July 17, 2025

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 101. No objections have been filed in response to the motion for default 84. Plaintiff's motion for default judgment is granted. Enter order. Mailed notice.

103

July 17, 2025

DEFAULT JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 7/17/2025. Mailed notice.

104

July 17, 2025

MINUTE entry before the Honorable Mary M. Rowland: The eighty-five-thousand-dollar ($85,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns, & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Mailed notice.

105

July 21, 2025

NOTICE of Removal of Material from the Custody of the Clerk's Office, Dckt. No. 27 Surety Bond in the amount of $85,000.00, posted by Crye Precision LLC. (Received at the Intake Counter on 7/21/25.)

106

July 24, 2025

FULL SATISFACTION of Judgment regarding Default Judgment 103 in the amount of $100,000 as to certain defendant

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