2025-cv-03773

COMPLAINT filed by Paddington & Company Ltd.; Filing fee $ 405, receipt number AILNDC-23317119.

Exhibit 1

Declaration of Martin F. Trainor

(Exhibit 1)

Exhibit 2, Part 1

Declaration of Martin F. Trainor

(Declaration of Martin F. Trainor)

Declaration of Sydney Fenton

(Exhibit A)

Declaration of Martin F. Trainor

(Exhibit A)

Exhibit A

Exhibit A

Exhibit A

Exhibit 1

Exhibit 1

Exhibit A

SEALED EXHIBIT by Plaintiff Paddington & Company Ltd. Schedule A regarding complaint 1

Exhibit 2

(Exhibit 1)

Exhibit 2, Part 2

(Exhibit 1)

(Exhibit A)

(Exhibit 1)

MOTION by Plaintiff Paddington & Company Ltd. for Leave to File Certain Documents Under Seal

Exhibit 3

Exhibit 2, Part 3

CIVIL Cover Sheet

(Exhibit 4)

Exhibit 2, Part 4

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Paddington & Company Ltd.

(Exhibit 2, Part 5)

Notice of Claims Involving Trademarks by Paddington & Company Ltd.

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Alexander Whang

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Heather K. McShain. 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: 2024 NEW FASHION Store, ALIEX PREESS B108 Store, Cute Children Clothes Store, HEIKA PC14 Store, Izagic Bags Store, MensTshirt Store, Relax Time Store, Sawyer Store, Shop1102650433 Store, Shop1102735121 Store, Shop1102841553 Store, Shop1102883199 Store, Shop1102901509 Store, Shop1102904454 Store, Shop1102994667 Store, Shop1103205871 Store, Shop1103645158 Store, Shop1103754421 Store, Shop1103781237 Store, Shop1103836687 Store, Shop1103936112 Store, Shop1104003302 Store, Yeshancen Store, YO YO Store, shanghaiqichengkejifuwuyouxiangongsi, ZWT Poster Shop, CardoonStore, EsanEmbroidery, MockUps123, NotJustNanasKnit, PetitePaperieUK, UnlimitedArtByCourt, WonkyCow, Aisha Brakus, Zhangzhoushi HonghaiDianzishangwuYouxiangongsi, Airpears, artsshoping, artswardrobe, caedice, Coodeals, designmgo, DORISTINO, fansells, Fanwells, Numeralpaint, offer-toy, ReverLavie, rockyrecs, saariley, Seseable, sistary, Spread T-shirt, sunaturehome, TokoPyramid, yornprints, Aalexandebernardurs, Anthea Turks and Caicos Islands Finch, GallardandHolland, PufnicaDesign, Splatter-arts, Yvonne Flannery, Soak up the studio, KEKAIFAN, KenGifts, yangsen, Shop1102999423 Store, Barbara Acat, yongjipeixingwangluojishuyouxiangongsi, alanduo, Diamondpaint.uk, Diamondpaintingskit.shop, idPoster and Prostargift added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

MAILED original ten-thousand-dollar ($10,000) surety bond to posted by Paddington & Company Ltd. through their attorneys Alexander Whang TME Law, P.C. 10 South Riverside Plaza 875 Chicago, IL 60606 via certified mail #7022 3330 0001 8848 7518. (jn,) (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Paddington & Company Ltd. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief 12

DECLARATION of Stewart Miller regarding memorandum in support of motion 13

SEALED EXHIBIT by Plaintiff Paddington & Company Ltd. Exhibit 2, Parts 1-5 regarding declaration 14

MOTION by Plaintiff Paddington & Company Ltd. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief 16

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 12, motion for miscellaneous relief 16, motion for miscellaneous relief 3 before Honorable Elaine E. Bucklo on 4/17/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file certain documents under seal 3 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery 12 ; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) 16 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 5/1/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/24/2025. Law TME Law, P.C. 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 6/2/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 5/27/2025, 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.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 4/17/2025. Mailed notice.

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

MOTION by Plaintiff Paddington & Company Ltd. to Extend the Temporary Restraining Order

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief 23

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 23 before Honorable Elaine E. Bucklo on 4/30/2025 at 09:45 AM.

SURETY BOND in the amount of $ 10,000.00 posted by Paddington & Company Ltd.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order 23 is granted to 5/15/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

SUMMONS Returned Executed by Paddington & Company Ltd. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 5/12/2025, answer due 6/2/2025.

MOTION by Plaintiff Paddington & Company Ltd. for preliminary injunction

MEMORANDUM by Paddington & Company Ltd. in support of motion for preliminary injunction 30

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction 30 before Honorable Elaine E. Bucklo on 5/15/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: The motion hearing on the motion for preliminary injunction 30 set for 5/15/2025 is stricken and reset to 5/21/2025 at 9:45 a.m. Mailed notice

MOTION by Plaintiff Paddington & Company Ltd. to Extend the Temporary Restraining Order

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 34 before Honorable Elaine E. Bucklo on 5/16/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Motion to extend the TRO 34 is granted. The TRO is extended until 5/21/2025, or until the motion for preliminary injunction is resolved. Motion hearing set for 5/16/2025 is stricken. Mailed notice

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction [30] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Stewart Miller [15], and the TRO [20]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 5/21/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

STATUS Report by Paddington & Company Ltd.

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff is in active settlement negotiations with multiple defendants. Plaintiff will move for default judgment against remaining non-dismissed defendants at a later date where appropriate. Status hearing is reset for 7/10/2025 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 7/3/2025. The court will enter an order in response to the status report. Mailed notice.

MOTION by Defendant Coodeals for release of funds. (Received via Box.com 6/2/25, Exhibits)

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

MOTION by Plaintiff Paddington & Company Ltd. for Entry of an Agreed Asset Restraint Order as to Defendant Nos. 37, 38, and 41

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[46] before Honorable Elaine E. Bucklo on 6/18/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Parties to take note of Judge Bucklo's motion call practice posted on her webpage at www.ilnd.uscourts.gov. The Court sets the following briefing schedule on Defendant Coodeals' motion for release of funds [44]: Plaintiff's response is due by 7/2/2025. Defendant's reply is due by 7/16/2025. Ruling before the Honorable Elaine E. Bucklo on 8/14/2025 at 9:30 a.m. Status hearing to stand as to remaining non-dismissed defendants. Mailed notice.

MINUTE entry before the Honorable Elaine E. Bucklo: Agreed Asset Restraint Order as to Defendant Nos. 37, 38, and 41 [46] is granted. Mailed notice.

AGREED ASSET RESTRAINT Order as to Defendant Nos. 37, 38, AND 41 signed by the Honorable Elaine E. Bucklo on 6/12/2025. Mailed notice.

MOTION by Plaintiff Paddington & Company Ltd. to strike MOTION by Defendant Coodeals for release of funds [44] (UNOPPOSED)

NOTICE of Motion by Sydney Paige Fenton for presentment of motion to strike[51] before Honorable Elaine E. Bucklo on 6/20/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's unopposed motion to strike motion for release of funds 44 51 is granted. Defendant Coodeals' for release of funds 44 and its briefing schedule and ruling date are stricken.Mailed notice.

STATUS Report by Paddington & Company Ltd.

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to the status report, plaintiff reports active settlement negotiations with multiple defendants. Plaintiff will move for default judgment at a later date where appropriate. Status hearing is reset for 8/26/2025 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 8/19/2025. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to certain Defendants

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to certain Defendants

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

MOTION by Plaintiff Paddington & Company Ltd. for entry of default, MOTION by Plaintiff Paddington & Company Ltd. for default judgment as to all Defendants

MEMORANDUM by Paddington & Company Ltd. in support of motion for entry of default, motion for default judgment[60]

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[61]

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment[60] before Honorable Elaine E. Bucklo on 8/22/2025 at 09:45 AM.

STATUS Report by Paddington & Company Ltd.

EXHIBIT by Plaintiff Paddington & Company Ltd. Exhibit A (CORRECTED) regarding MOTION by Plaintiff Paddington & Company Ltd. for entry of default MOTION by Plaintiff Paddington & Company Ltd. for default judgment as to all Defendants [60]

EXHIBIT by Plaintiff Paddington & Company Ltd. Exhibit A (CORRECTED) regarding status report[64]

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff's motion for entry of default and default judgment [60] against all defendants remaining in this case is granted. Enter Default Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff or Plaintiff's counsel, TME Law P.C. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/22/2025. Mailed notice.

RETURN of U.S. Post Office Receipt, article no. 7022 3330 0001 8848 7518.