2025-cv-03356

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-23273916.

Exhibit 1

SEALED EXHIBIT by Plaintiff Nike, Inc. Schedule A regarding complaint[1]

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

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: jiangsuruitengguandaoshebeiyouxiangongsi, liaochengshizhinandian-0, limei_7, lincangpujiaxuansh0, lincangtongxiyusha0, lingm-9, linhongli, lou258889, polun-83, qiabaihuo, qingqing831, quejl36, sanbai-1, scobb0705, sdf0722, shu584-70, svaisfa, teime9509, trendx258, tty568810, winway369, x-8769, xiaohuashangmao55, xuwei6262, yancy520, yangshuai626, Yayi, yhdjb26, yingmi-8076, yinmim88, yiwushihanpengfu-0, yunqiu239, yuso2568, zhiguiy, zuyn-15, lulu_zora9939, nancy.sneaker, nicole.bear6, nidialenni, venus_ortizy, wengdy1999, wengh12__, west668888, yingzi868668, zsneaker.xg, antsneakers.com, boom1950.ru, cckick.ru, joyfballx.com, liang4567.com, lo-trade.net, nkheaven.net, audreyvip, Cool-Kicks, crazyrep and HOLY KICKS added to case caption.

MAILED Surety Bond posted by Nike, Inc. to Amy Crout Ziegler at Greer, Burns & Crain Ltd. via certified mail no. 9589 0710 5270 0579 7838 82.

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

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

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for leave to file document under seal [3] is granted. As such, Schedule A to the complaint [2], provisionally under seal pending order, is permitted to remain under seal, and Plaintiff may file exhibit 2 to the Declaration of Joe Pallett under seal. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: By 3/8/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Minute entry [14] is corrected as follows: By 4/8/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

AMENDED complaint by Nike, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

SEALED EXHIBIT by Plaintiff Nike, Inc. Amended Schedule A regarding amended complaint[16]

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[18]

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

DECLARATION of Joe Pallett regarding memorandum in support of motion[19]

Exhibit 1

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 2 - Parts 1-2 regarding declaration[21]

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[23]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[24]

RESPONSE by Plaintiff Nike, Inc. to text entry, [15]

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 1 regarding Response[26]

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for electronic service [23] is granted. Plaintiff's motion for a temporary restraining order [18] is taken under advisement. By 4/14/25, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. Mailed notice

RESPONSE by Plaintiff Nike, Inc. to order on motion for temporary restraining order, order on motion for miscellaneous relief, terminate motions, [28]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO [18] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/10/2025. Mailed notice

Registry Deposit Information Form by Nike, Inc.

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

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

SURETY BOND in the amount of $ 56,000 posted by Nike, Inc. (Document not imaged)

MOTION by Plaintiff Nike, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Nike, Inc. in support of extension of time[36]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[37]

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order 36 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/22/2025. Mailed notice

MOTION by Plaintiff Nike, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[41]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[42]

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/1/2025, answer due 5/22/2025.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction 41 is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 5/6/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 5/2/2025. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 47, defendant nos. 18 and 19 are dismissed from this case. Mailed notice

MOTION by Plaintiff Nike, Inc. to approve consent judgment as to Certain Defendants

Exhibit 1

Exhibit A

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[50]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[51]

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:The joint motion for entry of a consent judgment as to defendant nos. 4, 20, and 28 49 is granted. Enter order. Mailed notice

CONSENT Judgment Signed by the Honorable John J. Tharp, Jr on 5/28/2025. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 50 is taken under advisement. Any objections or responses are due by 6/9/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 5/30/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, 55

Exhibit A

(Exhibit B)

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [57], defendant no. 13 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [50] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 6/10/2025. Mailed notice

EMAILED Trademark report with certified copy of minute order dated 6/10/25 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 60 in the amount of $175,000 as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 62, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 32. Mailed notice

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7838 82. (jn,)