2025-cv-03966

COMPLAINT filed by Revelyst Operations LLC ; Filing fee $ 405, receipt number AILNDC-23339917.

Exhibit 1 - TM Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC - Schedule A to Complaint - regarding complaint, 1

MOTION by Plaintiff Revelyst Operations LLC to seal document exhibit 3

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Revelyst Operations LLC

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Matthew A. Werber

MAILED trademark report to Patent Trademark Office, Alexandria VA.

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

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

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Peter Krusiewicz

MOTION by Plaintiff Revelyst Operations LLC for temporary restraining order PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

MEMORANDUM by Revelyst Operations LLC in support of motion for temporary restraining order 10 MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

Declaration of Paul Mills

Declaration of Matthew Werber

(Unpublished)

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT 1 TO THE DECLARATION OF PAUL MILLS (SEALED) regarding memorandum in support of motion, 11

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT A TO THE DECLARATION OF MATTHEW A. WERBER (SEALED) regarding memorandum in support of motion, 11

MEMORANDUM by Revelyst Operations LLC -- MEMORANDUM ON JOINDER --

MOTION by Plaintiff Revelyst Operations LLC FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE

Declaration of Matthew Werber

Exhibit A - to the Declaration of Matt Werber

Exhibit B - to the Declaration of Matt Werber

(Unpublished)

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal 4, ex parte motion for a temporary restraining order, including a temporary injunction and a temporary asset restraint 10, and motion for expedited discovery, and for electronic service of process 15 are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 6/20/25 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 5/8/2025. Mailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Revelyst Operations LLC

ATTORNEY Appearance for Defendant Jimtye by Qin Zhuang

Notice by Revelyst Operations LLC -- 10,000 USD surety bond deposited 05/13/25 --

MOTION by Plaintiff Revelyst Operations LLC PLAINTIFF'S MOTION TO EXTEND TEMPORARY RESTRAINING ORDER

ATTORNEY Appearance for Defendants BontokDirect, Anovo by Jing An

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the temporary restraining order 20 is granted. The TRO entered on 5/8/25 is extended to 6/5/25. Mailed notice

SUMMONS Issued (Court Participant) as to Defendant BontokDirect

SUMMONS Returned Executed by Revelyst Operations LLC as to All Defendants.

(Declaration)

MOTION by Plaintiff Revelyst Operations LLC for preliminary injunction

(Unpublished Cases)

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 28. 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 or before June 13, 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 order entering the TRO, the TRO is extended to and including the date upon which 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 Fed.R.Civ.P. 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 Peter Krusiewicz on behalf of Revelyst Operations LLC regarding text entry, 30

MOTION by Defendants Anovo, BontokDirect for extension of time to file answer

MINUTE entry before the Honorable Jeffrey I Cummings: Defendants BontokDirect and Anovo's unopposed motion for extension of time to answer or otherwise plead 32 is granted. Defendants BontokDirect and Anovo shall answer or otherwise plead by 6/16/25. Mailed notice. (jn,)

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to certain defendants

MINUTE entry before the Honorable Jeffrey I Cummings: The Court's 6/6/25 order 33 is amended to reflect that defendants BontokDirect and Anovo shall answer or otherwise plead by 7/16/25. Mailed notice

MOTION for Leave to Appear Pro Hac Vice on behalf of MIZUGIWA by YU WENZHU; Filing fee $ 150, receipt number AILNDC-23612320.

MOTION for Leave to Appear Pro Hac Vice on behalf of Wealucky by YU WENZHU; Filing fee $ 150, receipt number AILNDC-23612338.

NOTICE of Voluntary Dismissal by Revelyst Operations LLC -- as to certain defendants --

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jeffrey I Cummings: Attorney Wenzhu Yu's motion for leave to appear pro hac vice 36 is granted. Attorney Whenzhu Yu's second motion for leave to appear pro hac vice 37 is denied as moot as only one pro hac vice request is required per proceeding. See Local Rule 83.14 ("A member in good standing of the bar of the highest court of any state of or any United States district court may, upon motion, be permitted to argue or try a particular case in whole or in part."). Mailed notice

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MOTION by Defendants MIZUGIWA, Wealucky for extension of time to file

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MEMORANDUM by Wealucky in Opposition to motion for preliminary injunction 28

Exhibit

Exhibit

Exhibit

Declaration

(Declaration)

MOTION by Plaintiff Revelyst Operations LLC for extension of time to file response/reply as to memorandum in opposition to motion 45 - UNOPPOSED MOTION TO EXTEND TIME FOR REPLY UNTIL AUG. 4 -

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jeffrey I Cummings: Defendants' motion for extension of time 43 is granted and the Court has since received the response brief filed by defendants Mizugiwa and Wealucky. Plaintiff's motion for extension of time to file a reply brief 46 is granted and plaintiff's reply in support of the motion for preliminary injunction is due 8/4/25. The parties are also encouraged to continue to engage in settlement negotiations and shall file a joint status report on settlement by 8/13/25. The previously set 6/20/25 tracking status hearing is stricken and re-set to 9/19/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MOTION by Plaintiff Revelyst Operations LLC for default judgment as to Defaulting Defendants

MEMORANDUM by Revelyst Operations LLC in support of motion for default judgment 49

Ex. A - Defaulting Defendants

Werber Decl

Unpublished - 25-cv-04431

(Other Unpublished)

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to certain defendants

ATTORNEY Appearance for Defendant Homesafety Electronic Co.,Ltd. by Ni Xue

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Homesafety Electronic Co.,Ltd.

MOTION by Defendant Homesafety Electronic Co.,Ltd. for extension of time to file answer regarding complaint, 1

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jeffrey I Cummings: In light of plaintiff's notice of voluntary dismissal of defendant Homesafety Electronic Co. 55, defendant's motion for extension of time to answer or otherwise plead 54 is denied as moot. Mailed notice. (jn,)

REPLY by Revelyst Operations LLC to memorandum in opposition to motion 45 -- CORRECTED REPLY BRIEF re DKT 56 --

Mills Decl.

Werber Decl.

Ex. A

Ex. B

Ex. C

Ex. D

Ex. E

Ex. F

Ex. G

(Ex. H)

MOTION by Plaintiff Revelyst Operations LLC to strike memorandum in support of motion, 56 and replace with Corrected Reply at Dkt. 58

REPLY by Plaintiff Revelyst Operations LLC to memorandum in support of motion, 56 -- SECOND CORRECTED REPLY REPLACING 56 and 58 --

Mills Decl.

Werber Decl.

Ex. A

Ex. B

Ex. C

Ex. D

Ex. E

Ex. F

Ex. G

(Ex. H)

MOTION by Plaintiff Revelyst Operations LLC to strike reply to response to motion, 58, memorandum in support of motion, 56 and Replace with Second Corrected Reply Brief 60

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to withdraw and strike reply briefs 61 is granted in light of plaintiff's second corrected reply 60. The previously filed motion to withdraw and strike 59 is denied as moot. Mailed notice

STATUS Report on Settlement re Dkt. 48 by Revelyst Operations LLC

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiff's status report on settlement 64, which indicates that the parties have discussed settlement and plaintiff is hopeful those discussions will continue. The Court encourages the parties to continue to meet and confer in an effort to resolve their dispute. They shall file a joint status report on settlement by 9/25/25. The 9/19/25 tracking status hearing is stricken and re-set to 10/3/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice.

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 49 for entry of default and default judgment against all defaulting defendants (which does not include defendants Wealucky and MIZUGIWA. All remaining defaulting defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of 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 8/29/25. 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. Mailed notice

CERTIFICATE of Service Pursuant to Court's Minute Order (Dkt. 66) by Peter Krusiewicz on behalf of Revelyst Operations LLC regarding text entry, 66

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

STATUS Report by Revelyst Operations LLC