2025-cv-03147

COMPLAINT filed by Lululemon Athletica Canada Inc.; Filing fee $ 405, receipt number AILNDC-23254697.

Exhibit 1

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Lululemon Athletica Canada Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lululemon Athletica Canada Inc.

Notice of Claims Involving Trademarks by Lululemon Athletica Canada Inc.

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Lululemon Athletica Canada Inc. by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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: Dongguan Jijin Leather Goods Co., Ltd., Dongguan Zhixin Clothing Co., Ltd., Gansu Fanxi Trading Co., Ltd., Guangzhou Dingtai Clothes Co., Ltd., Hangzhou Yuanzhe Clothing Technology Co., Ltd., Nanyang Zhuoyufang Trading Co., Ltd., Shenzhen Crossing Light Boat Technology Co., Ltd., Shenzhen Jiamei Sports Development Co., Ltd., Shenzhen Runningline Instrument Co., Ltd., Shenzhen Shenlangxuan Leather Case Co., Ltd, Yiwu Xuer Trading Co., Ltd., Zhaoqing Boheng Clothing Co., Ltd., Sehcahe, 88aaww, daichuangsheng, gwx86dn, hangyinhanshangmao, hao43567, henggeng9, jinbo372, jiujiangrunandian, ngzhouyanku, qzfzd-42, taiyang77, vnqqqms_85, wenjun374, yujilin98, zhizhi851, xiuxiu1363, chunwcz, ALOO, Big Bird, Highend Bags, jinanqingdaifushi, NovaGlobal, Oxes, SHILIUU, SHISAN, SHIWU, Sunmood, lululemon-me.shop, lululemon-home.shop, lululemoutlet.live, lululemonyoga.shop, lululemons-eu.com, lululemonclubs.com and botanirdens.shop added to case caption.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal [3] is granted. Mailed notice.

MOTION by Plaintiff Lululemon Athletica Canada Inc. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

DECLARATION of Jenny Vo regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Lululemon Athletica Canada Inc. Exhibit 2 Parts 1-2 regarding declaration[15]

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

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[17], motion for temporary restraining order[12] before Honorable Charles P. Kocoras on 4/1/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for temporary restraining order [12] and motion for electronic service of process [17] are granted. Enter Temporary Restraining Order. Presentment hearing scheduled on 4/1/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 3/28/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Lululemon Athletica Canada Inc.

Registry Deposit Information Form by Lululemon Athletica Canada Inc.

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

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Edmond E. Chang for all further proceedings pursuant to 28 USC 294(b). Mailed notice

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

MOTION by Plaintiff Lululemon Athletica Canada Inc. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for preliminary injunction[30]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[30] before Honorable Edmond E. Chang on 4/10/2025 at 08:30 AM.

Exhibit A

SUMMONS Returned Executed by Lululemon Athletica Canada Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/7/2025, answer due 4/28/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable Edmond E. Chang: Given the applicability of the same circumstances that justified entry of the initial TRO, the motion for preliminary injunction 30 is granted. In light of the answer deadline of 04/28/2025, R. 33, and to track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 05/16/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a joint status report by 05/09/2025. For those Defendants who have not answered on time, they are deemed to be in default, and the Plaintiff shall file a motion for default judgment by 05/09/2025. ****In the motion for default judgment, the Plaintiff must include a chart that sets forth, with citations to the record, a seller-by-seller listing of the price of the infringing goods, the number of reviews (if any) for the goods, the number of reviews (if any) for the seller, and when the seller began operating on the platform (if the date is available).*** Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 04/09/2025. Emailed notice

SUMMONS Returned Executed by Lululemon Athletica Canada Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/9/2025, answer due 4/30/2025.

Declaration of Jennifer V. Nacht

(Exhibit A)

MOTION by Plaintiff Lululemon Athletica Canada Inc. for entry of default, MOTION by Plaintiff Lululemon Athletica Canada Inc. for default judgment as to all remaining Defendants

Exhibit A

MEMORANDUM by Lululemon Athletica Canada Inc. in support of motion for entry of default, motion for default judgment, [37]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[38]

Exhibit 1

Exhibit 2

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [37] before Honorable Edmond E. Chang on 5/16/2025 at 08:30 AM.

Exhibit A

MINUTE entry before the Honorable Edmond E. Chang: On review of the motion [37] for default judgment, the Court allowed the prior joinder that was authorized by the previously assigned judge. But in setting statutory damages, an examination of R. 16-1 reveals different types of infringing goods, sold at a wide variety of different prices, and by sellers with a wide variety of reviews (many of which are zero or one review). As explained in the Order, a $20,000 statutory damages award was appropriate per Defendant. Given the finding of willfulness established by the default, a permanent injunction shall be entered. A separate AO-450 judgment shall be entered. The status hearing of 05/16/2025 is vacated. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 05/12/2025. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 05/12/2025. Emailed notice

MAILED final trademark report with a copy of the minute entry 41, final judgment order 42, and judgment entered 43 to Patent Trademark Office, Alexandria VA

NOTICE of withdrawal of Surety Bond [29] by Counsel/Designated person. (Received at the Intake Counter on 9/11/2025)