2025-cv-03991

COMPLAINT filed by Anna Melis; Filing fee $ 405, receipt number AILNDC-23342970.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Anna Melis Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Anna Melis by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Anna Melis by Yanling Jiang

ATTORNEY Appearance for Plaintiff Anna Melis by Yi Bu

ATTORNEY Appearance for Plaintiff Anna Melis by Adam Grodman

ATTORNEY Appearance for Plaintiff Anna Melis by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Anna Melis by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Anna Melis by Christopher Romero

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 3).

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: WNC66, putianchengxiangquliangwangxibaihuoshanghang, Ling Yi Trading Company, JBEELATE, Mistshopy, Radmire-Belts, wanzaiwuxi, Whrounnk, Jonathan Murra, MAYBEcuy, PANGERSOUR, menglicha, Huizhirem, jinboy, lovemsy, LanSha-us, xuanyuyu, Shidifensen and Covvoliy added to case caption.

NEW PARTIES: Cao Anhs, supcoo, WARMISH Phoebebee, Ouxeer, JowenShop, SinCoome, Ladily, ZDRZK Direct Online, Shuohui Shop, Ahaigestyle, Quinni Mall, ZHONGShen, GUANGZHOUZHONGYISHANGMAOYOUXIANGONGS I, ChristmasFunnn, yongjingxianshengcaishangmaoyouxiangongsi, FengYangXianHanHangShiShangMao, STZYY, DragonDesignGifts, Lanfashionhn, luliamenton, AISILLI, Great House No1, ZhilanGebang, SUSUYC, TENGDAWYP, HONGZHONG, SoulPig and WUISTORE added to case caption.

NEW PARTIES: NGGGN, Love Boutique, WEIREN, WangDamai, ATTiger, tongqiuda, antengus, XYL01, NewCharmy, FRGITYGIFT, POISPOIS, SuperClogs, BibHoly-US, MYH01, Showlife, LUAOX, wuguoqian789, shuixincheng, hyxcd, Menore, Season Tour, Tufeiwenhua, HSJIANG, ruidonglingshoude, bushkb, Aboyal, LNQWER, qiaolincheng, Braturpoe, zhuangzhouus, XIAONAJIE, foshanshiguanyasenbaomaoyiyouxiangongsi, duorou naicha, Tarvione, Cyber Monday Christmas paehe, yingrandianzi, HmongCo, YOOHOO Clothes, Brewee, YingJing US, Xiangwenwen, DISENB, DazzlingMs, IAIHDUAU, 53wuyongquan, MIMIGOGO Kidsfashion, Jhbxhhd, QUDDERR CLOTHING, YTDSCS Co.Ltd, MERSARIPHY ONLINE STORE, BemeyourBBs, Stringdie, Tersarium, Narrster, Alfierk, Sparsain, Melantax, Reiouss, izationg, Eeristq, Parvistic, LIYUNJING, GORGECRAFT, Jingyao WT, wowotier and yuyuyi added to case caption.

NEW PARTIES: Iumwxz.Ltd, Zeiyignr, ZUBKTE, kasoj, SdToygd, Beforeyayn, Vivianyo HD, WAITLOVER, evhno, LKHLAO, DUNENG Co.Ltd, DONGXUAN Co.Ltd, JUNZHOU Co.Ltd, WWANGTAO, CAIBO Diy Decoration, YOUBAIJIA, Yi Yong Co., Ltd., PanKo Shop, QuJingKaiFaQuMengDuoDianZiShangWuYouXianGongSi, huangcan, taiyuanyuchaozechangbaihuomao, Le cishi Company, DAKIMOE, Raruxxin Fashion, JPlongge, JPZJAA, FREEDA, Hello go case, Fzahinter, Meimei Shell, LEDOO Collection, Ai jie case, RELAXYOLO, Hi turn the whole game around, I like it myself banone, Fashion Waker, Nerinvi QT, Pinnacle Menswear, Sundacen, XUNZ, PrimePrinted, Rongyan Fashion, Street clothing community, SetonTee, CASDAMNA, FHJUHYG and Feiyangdxin added to case caption.

NEW PARTIES: MR LLIANG, Pacifico LLUO, Digital Ocean, Black npowder, yologo, Jyotri, coral case, C Newcase, boom pink, KGHYHUJTT, WTY GJ, chanxifengge, Faris, Xiaoyes clothing, VIENOER, Mai Le Fashion, Sujohand, WOMENS CLOTHES STUDIO, Defendant 18, Defendant 34, Defendant 82, Defendant 87, Defendant 90, Defendant 94, Defendant 182 and Defendant 195 added to case caption.

MINUTE entry before the Honorable John J. Tharp, Jr: By 4/22/25, 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

MAILED Copyright report to Registrar, Washington DC.

MOTION by Plaintiff Anna Melis for extension of time to Comply with Minute Entry 11

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for extension of time 13 is granted. The plaintiff's supplement is due 5/6/2025. Mailed notice

MOTION by Plaintiff Anna Melis for leave to file under seal

MOTION by Plaintiff Anna Melis for leave to file excess pages

MEMORANDUM in support of 17 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Anna Melis

(Exhibit 1, of Anna Melis' declaration)

SEALED EXHIBIT by Plaintiff Anna Melis Sealed Exhibit 2, Declaration of Anna Melis regarding memorandum in support of motion, 18

(Exhibit 2-1)

SUPPLEMENT to Supplemental Information in Support of Plaintiff's Motion 17 for Temporary Restraining Order

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 17 is granted. Plaintiff's motions for leave to file under seal 15 and to exceed page limitation 16 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 4/25/2025. Mailed notice

SUMMONS Issued (Court Participant) as to Defendant WNC66 and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 200,000 posted by Anna Melis (Document not scanned)

ATTORNEY Appearance for Defendants Jinsine, Ladily by Steven G Kalberg

MOTION by Plaintiff Anna Melis for preliminary injunction

MEMORANDUM by Anna Melis in support of motion for preliminary injunction 27

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

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

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's declaration

(Exhibit 2, of Keith A. Vogt's declaration)

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 27 is taken under advisement. Any objection or response is due before 5/9/25. Upon review of the certificate of service, the Court directs the plaintiff, by 5/7/25, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 5/9/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

DOCUMENT REMOVED ENTERED IN ERROR (Additional attachment(s) added on 5/6/2025: # 1 REMOVAL).

ATTORNEY Appearance for Defendants CHUONI Co.Ltd, PINGXIAO Co.Ltd, WEIRUN Co.Ltd, YUNJIN Co.Ltd, QIANSHAN Co.Ltd, HENGPING Co.Ltd, LINGYANG Co.Ltd, LONGSHI Co.Ltd, LIQUAN Co.Ltd, QUANLONG Co.Ltd, SHUNDONG Co.Ltd, ZUOYU Co.Ltd, FANGLIU Co.Ltd by He Cheng

RESPONSE by CHUONI Co.Ltd, FANGLIU Co.Ltd, HENGPING Co.Ltd, LINGYANG Co.Ltd, LIQUAN Co.Ltd, LONGSHI Co.Ltd, PINGXIAO Co.Ltd, QIANSHAN Co.Ltd, QUANLONG Co.Ltd, SHUNDONG Co.Ltd, WEIRUN Co.Ltd, YUNJIN Co.Ltd, ZUOYU Co.Ltdin Opposition to MOTION by Plaintiff Anna Melis for preliminary injunction 27

Exhibit Ex. 1 - Screenshot evidence provided by Plaintiff

Exhibit Ex. 2 - Similar cases filed by Plaintiff

Exhibit Ex. 3 - Declaration in support of Defendants' opposition for Defendant FANGLIU Co.Ltd

Exhibit Ex. 4 - Declaration in support of Defendants' opposition for Defendant HENGPING Co.Ltd

Exhibit Ex. 5 - Declaration in support of Defendants' opposition for Defendant LIQUAN Co.Ltd

Exhibit Ex. 6 - Declaration in support of Defendants' opposition for Defendant LINGYANG Co.Ltd

Exhibit Ex. 7 - Declaration in support of Defendants' opposition for Defendant LONGSHI Co.Ltd

Exhibit Ex. 8 - Declaration in support of Defendants' opposition for Defendant ZUOYU Co.Ltd

Exhibit Ex. 9 - Declaration in support of Defendants' opposition for Defendant PINGXIAO Co.Ltd

Exhibit Ex. 10 - Declaration in support of Defendants' opposition for Defendant SHUNDONG Co.Ltd

Exhibit Ex. 11 - Declaration in support of Defendants' opposition for Defendant YUNJIN Co.Ltd

Exhibit Ex. 12 - Declaration in support of Defendants' opposition for Defendant QIANSHAN Co.Ltd

Exhibit Ex. 13 - Declaration in support of Defendants' opposition for Defendant CHUONI Co.Ltd

Exhibit Ex. 14 - Declaration in support of Defendants' opposition for Defendant WEIRUN Co.Ltd

(Exhibit Ex. 15 - Declaration in support of Defendants' opposition for Defendant QUANLONG Co.Ltd)

MOTION by Defendants CHUONI Co.Ltd, FANGLIU Co.Ltd, HENGPING Co.Ltd, LINGYANG Co.Ltd, LIQUAN Co.Ltd, LONGSHI Co.Ltd, PINGXIAO Co.Ltd, QIANSHAN Co.Ltd, QUANLONG Co.Ltd, SHUNDONG Co.Ltd, WEIRUN Co.Ltd, YUNJIN Co.Ltd, ZUOYU Co.Ltd for leave to file this Opposition 33 to Plaintiff's Motion for Entry of a Preliminary Injunction

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by CHUONI Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FANGLIU Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HENGPING Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LINGYANG Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LONGSHI Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by PINGXIAO Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LIQUAN Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by QIANSHAN Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by QUANLONG Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by SHUNDONG Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by WEIRUN Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by YUNJIN Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ZUOYU Co.Ltd

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for leave to file an untimely objection to the plaintiff's motion for a preliminary injunction 34 is granted. Defendant Nos. 130, 131, 132, 133, 134, 135, 137, 138, 139, 141, 142, 143, and 144 ("the objecting defendants") have objected to the motion for preliminary injunction against them 27. The plaintiff's reply is due 5/27/25. The TRO will be extended against the objecting defendants beyond the 28-day limit while the motion for preliminary injunction is pending, i.e., until the Court reaches a decision on the motion. This extension is technically a conversion of the TRO to an enforceable preliminary injunction subject to appellate review. H-D Michigan, LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 844-45 (7th Cir. 2012) (holding that a district court may extend the duration of a TRO beyond the statutory limit and without consent of the enjoined party until it reaches a decision on a preliminary injunction by technically converting the TRO into an enforceable preliminary injunction subject to appellate review). Mailed notice

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 27 is granted as to all defendants except defendant nos. 130, 131, 132, 133, 134, 135, 137, 138, 139, 141, 142, 143, and 144. 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 5/14/25 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 5/13/2025. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

ATTORNEY Appearance for Defendant Defendant 34 by Hongchang Deng. According to the information provided by Plaintiff, Defendant No. 34 is Mavis s Diary.

MOTION by Defendant Defendant 34 for extension of time to file answer regarding complaint 1 According to the information provided by Plaintiff, Defendant No. 34 is Mavis s Diary.

MOTION by Plaintiff Anna Melis to stay regarding order on motion for leave to file, terminate motions, 48 Joint Notice of Settlement and Motion to Stay Briefing Schedule Set in Minute Entry Order 48

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) 51, the defendants identified therein are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The motion for extension of time 53 is granted. Defendant no. 34 Mavis's Diary's answer or otherwise responsive pleading is due 6/26/2025. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The joint motion to stay briefing in light of ongoing settlement discussions 54 is granted. The plaintiff's reply to the objecting defendants, see ECF No. 48, is extended until 6/27/25. Any stipulation of dismissal as to all objecting defendants will moot this deadline. Mailed notice

MOTION by Plaintiff Anna Melis for judgment Joint Motion for Entry of Consent Judgment as to Certain Defendants

MOTION by Plaintiff Anna Melis for default judgment as to the Defendants Identified in First Amended Schedule A

(Exhibit 1)

MEMORANDUM by Anna Melis in support of motion for default judgment 59

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable John J. Tharp, Jr:The joint motion for entry of a consent judgment as to defendant nos. 130, 131, 132, 133, 135, 138, and 139 58 is granted. Enter order. Mailed notice

CONSENT Judgment Order Signed by the Honorable John J. Tharp, Jr on 5/30/2025. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs 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) 63, the defendants identified therein are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 59 is taken under advisement. Any objections or responses are due by 6/12/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 6/4/25. 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

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MINUTE entry before the Honorable John J. Tharp, Jr:All responding or objecting defendants having been dismissed from this action, the plaintiff's motion for default judgment as to specific defendants 59 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 6/16/2025. Mailed notice

(CORRECTED) Default Judgment Order with attachment. Signed by the Honorable John J. Tharp, Jr on 6/16/2025. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notices of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) 66 70, the defendants identified therein are dismissed from this case. Mailed notice