2025-cv-03054

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co., Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23244813.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co., Limited Complaint for Copyright Infringement regarding complaint, [1]

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 3).

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: AirZeal, HugeNice, LYANER, Miskely, QITOHK, TraStuts and Lachmose added to case caption.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited to seal

Declaration of Katherine M. Kuhn in Support of Motion to Seal

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co., Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited to seal [4]

(Exhibit 2 to the Declaration of K. Kuhn)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co., Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co., Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co., Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co., Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co., Limited by Gokalp Bayramoglu

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for leave to file under seal [4] is granted for ONLY fourteen (14) days. Status hearing set for 4/11/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 4/4/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for service by publication and Electronic Service

Exhibit Memorandum In Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn in Support of Motion for Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for temporary restraining order

Exhibit Memorandum in Support of Motion for temporary Restraining Order

Declaration of Katherine M. Kuhn. in Support of Motion for Temporary Restraining

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Temporary Restraining Order

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for service by publication, [12], motion for temporary restraining order, [13] before Honorable Elaine E. Bucklo on 4/9/2025 at 09:45 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for leave to file excess pages for Temporary Restraining Order

STATUS Report in Compliance with Docket 11 by Hong Kong Leyuzhen Technology Co., Limited

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. The Clerk of Court is directed to unseal the following sealed documents: Sealed complaint and exhibits, Docket # [2]. Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [12]; Plaintiffs' Ex Parte motion for entry of temporary restraining order [13]; and Plaintiffs' motion to exceed page limitations [15] granted. Enter Temporary Restraining Order. Because the temporary restraining order will expire on 4/23/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/16/2025. The Law Offices of Konrad Sherinian, LLC is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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. The case is set for a status hearing on 5/27/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 5/20/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

TEMPORARY Restraining Order signed by the Honorable Elaine E. Bucklo on 4/9/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto by Plaintiff Hong Kong Leyuzhen Technology Co., Limited

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co., Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 4/16/2025, answer due 5/7/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for preliminary injunction

Memorandum of Law in Support of Motion for Preliminary Injunction

Declaration of J. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [22] before Honorable Elaine E. Bucklo on 4/23/2025 at 09:45 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for leave to deposit funds into court register [24] is granted. Pending the required bond deposit as ordered in the Temporary Restraining Order entered on 4/9/2025, Plaintiff's motion for preliminary injunction [22] is denied without prejudice. The motion is to be re-noticed consistent with Judge Bucklo standing order. Mailed notice.

SURETY BOND in the amount of $ $5,000.00 posted by Hong Kong Leyuzhen Technology Co., Limited

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co., Limited ONLY AS TO DEFENDANT NO. 3 WITH PREJUDICE

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for preliminary injunction (Renewed)

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S RENEWED MOTION FOR PRELIMINARY

Declaration of J. Droter in Support of Renewed Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [28] before Honorable Elaine E. Bucklo on 5/9/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's (renewed) motion for entry of a preliminary injunction 22 ; 28 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal ALL documents previously filed under seal. Mailed notice.

NOTICE of Voluntary Dismissal by Hong Kong Leyuzhen Technology Co., Limited ONLY as to Defendant 5

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co., Limited for default judgment as to 5 Defendants

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default Judgment

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [32] before Honorable Elaine E. Bucklo on 5/23/2025 at 09:45 AM.

STATUS Report in Compliance with Docket 17 by Hong Kong Leyuzhen Technology Co., Limited

ORDER for PRELIMINARY INJUNCTION signed by the Honorable Elaine E. Bucklo on 5/27/2025. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. Plaintiff's motion for entry of default and default judgment against the identified Schedule "A" defendants [32] is granted. Enter Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of five thousand dollars ($5,000) to Plaintiff or its counsel, Bayramoglu Law Offices. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 5/27/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order[37] ONLY as to Defendants 1, 2, 6 and 7