2025-cv-03844

COMPLAINT filed by Nike, Inc.; Filing fee $ 405, receipt number AILNDC-23327215.

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

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

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

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

Order on Motion for Preliminary Injunction

NEW PARTIES: lexsan Store, Shop1103655034 Store, Shop1104157401 Store, Shop1104160387 Store, Shop1104166384 Store, Tinti Sports Store, Yibo Sports Store, caizonglin, CiZouShangMaoYouXianGongSi, DFSDA2332, FANVOSSEM, fujianxinqiaomajiaoyukejiyouxiangongsia, Gxxx, HaErBinZhanHouBuShangMaoYouXianGongSi, ihtha, sitong, xinyexianminglongjiaoliushangmaoyouxiangongsi, Yizekeji, lincanghongcenhangs_0, lincanghuachuxiaosh0, lincangkaifenghaosh_0, lincangkaimengbaish-0, lincangshengfumosh_0, lincangzimingyusha_0, liujing_666, liuyangshicongpinggo0, lsland330, luluya758, luogangmaoyi68, mazengzhan_6, nanyangshishifengshan_0, noah_thetheu, nodin_bramson, o18212, Orange028, Ourclothing2, piannia_38, pingxu-8627, prq643, qboo778, qiaorongque, qinhuangdaominjiash_0, qinhuangdaotuanbaos0, qinhuangdaoxinpeish-0, qinia_99, ranyue_965, reimay259, rkshen-57, romanesque57, s61593luo, shsfgf, Strength555, sunjianyuan_852, tielingshifanqiujuns0, tielingshirongxulang0, u_5824, w52911, wanlan9, wuliqin_1, xeko2237, ximengmaoyiy, yanjinfuneifuzhu_0, yanjinquanlushan_0, yelco7, yunchengyanhudistrictorang0, z49291, zengrenjun, zhangzhenxing2, zhijiangshipingzandian_0, zre973, demi294, duxinghudu, ghuiahsd, lindan5151, lucysneakercc, mackluxlover, mslivip166, qysneakers, tudfulharamara, zfr168165, Kickzlucas, cocofashion124, my.shoes84, jujiadianzi, bluesky-footballshirt.com, cutejersey.com, foursneaker.com, kicks2024.com, mydopekicks.co, superkicks.store, vskicks.com, Coco1to1, 001-yang-888, 007repclub, 008-aya, babwholesale, Melissa Aahluxury and reprfactorys added to case caption.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by April 17, 2025 the Court may dismiss this matter for failure to prosecute. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

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[14]

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

DECLARATION of Joe Pallett regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Nike, Inc. Exhibit 2 - Parts 1-3 regarding declaration[17]

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[19]

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

SEALED DOCUMENT by Plaintiff Nike, Inc. Schedule A Template per [11]

Registry Deposit Information Form by Nike, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Nike, Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified in the Complaint

SURETY BOND in the amount of $ 10,000.00 posted by Nike, Inc. (Document not imaged) (Received via the Clerk's Office drop box on 04/18/25.)

MOTION by Plaintiff Nike, Inc. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by Nike, Inc. in support of motion for preliminary injunction[29]

Declaration of Marcella D. Slay

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/24/2025, answer due 5/15/2025.

Declaration of Berel Y. Lakovitsky

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by May 1, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for preliminary injunction, text entry, 32

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 29 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 33 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: DUPLICATE OF 34. Plaintiff's motion for a preliminary injunction 29 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 33 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: By May 22, 2025, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

SUMMONS Returned Executed by Nike, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/5/2025, answer due 5/26/2025.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

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

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Lindsay C. Jenkins on 5/20/2025. Mailed notice.

STATUS Report Pursuant to 36 by Nike, Inc.

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

MINUTE entry before the Honorable Lindsay C. Jenkins: By May 30, 2025, Plaintiff shall update the court on any remaining work to be done in the case in light of the stipulation of dismissal filed at docket entry [41] and the representations made in the most recent status report. If Plaintiff intends to seek default judgment as to any remaining defendant, it must be filed by that date. Mailed notice.

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[43]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[44]

Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before June 6, 2025. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by June 4, 2025. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff Nike, Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, 46

(Exhibit A)

STATUS Report Pursuant to 42 by Nike, Inc.

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

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 43 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The Clerk is directed to return the surety bond posted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 6/9/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding entered judgment 51 in the amount of $50,000 as to certain defendants