2025-cv-04071

COMPLAINT filed by Guangdongsheng Shunhechuanmei Co., Ltd.; Filing fee $ 405, receipt number AILNDC-23349791.

Exhibit Exh 1 - An Infringing Product

Exhibit Exh 2 - US Pat D1038258

Exhibit Exh 3 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 4 - Alibaba, Amazon, and Counterfeiting in the Age of the Internet

Exhibit Exh. 5 - Combating Trafficking in Counterfeit and Pirated Goods

(Exhibit Exh 6 - U.S. PTO Approval Certificates of Correction of Inventorship)

SEALED DOCUMENT by Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. Schedule A to Complaint

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. by Konrad Val Sherinian

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 1). (qrtr,)

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. (qrtr,)

ATTORNEY Appearance for Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. by Depeng Bi

MINUTE entry before the Honorable Sara L. Ellis: The initial status conference in this matter is set for 6/12/2025 at 1:30 p.m. The parties are directed to review the procedures and requirements for this conference on Judge Ellis' website and to submit the required Initial Status Report by 6/4/2025. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

MOTION by Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. for temporary restraining order

MEMORANDUM by Guangdongsheng Shunhechuanmei Co., Ltd. in support of motion for temporary restraining order 8

DECLARATION of Konrad Sherinian regarding motion for temporary restraining order 8

Exhibit Exh. 1 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 2 - Hague Convention

Exhibit Exh. 3 - Civil Procedure Law of the People's Republic of China

(Exhibit Exh. 4 - Binder of Unreported Cases)

DECLARATION of Wei Gao regarding motion for temporary restraining order 8

(Exhibit Exh 1 - US Pat No D1006076)

SEALED DOCUMENT by Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. Exh 2 to Dec Wei Gao

MOTION by Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. to seal document sealed document 2, sealed document 12

MOTION by Plaintiff Guangdongsheng Shunhechuanmei Co., Ltd. for leave to file excess pages

NOTICE of Motion by Konrad Val Sherinian for presentment of motion for leave to file excess pages 14, motion for temporary restraining order 8, motion to seal document 13 before Honorable Sara L. Ellis on 4/23/2025 at 09:45 AM.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Guangdongsheng Shunhechuanmei Co., Ltd.

NOTIFICATION OF CLAIMS INVOLVING PATENTS by Guangdongsheng Shunhechuanmei Co., Ltd.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for leave to file under seal 13 and for leave to file excess pages 14. The Court denies Plaintiff's motion for temporary restraining order 8 without prejudice. Plaintiff filed this case against 54 defendants for design patent infringement. Under Rule 20, a plaintiff may join multiple defendants in a single action if: (1) the claims against them are asserted with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) a question of law or fact common to all defendants exists. Fed. R. Civ. P. 20(a)(2)(A)(B). In reviewing the filings in this case, it does not appear that joinder is proper as to all Defendants. As the Court stated in Roadget Business Pte. Ltd. v. The Individuals, Corporations, Limited Liability Cos., Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, alleging that multiple defendants have infringed on the same copyright, trademark, or patent in the same way, without more, does not create the substantial evidentiary overlap required to find joinder proper. No. 23 C 17036, 2024 WL 1858592, at *67 (N.D. Ill. Apr. 29, 2024). The Court directs Plaintiff to file an amended complaint by 5/23/2025, as well as a statement on joinder explaining how the remaining Defendants comply with the Court's order in Roadget. The Court also cautions Plaintiff that, in order to support preliminary injunctive relief, it must show that the named defendants' alleged infringement remains active and ongoing. The Court thus orders Plaintiff to ensure that it only seeks preliminary injunctive relief from defendants whose alleged infringement remains active and ongoing. The Court sets a status hearing for 6/10/2025 at 9:30 AM. Status hearing set for 6/12/2025 is stricken. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

NOTICE of Voluntary Dismissal by Guangdongsheng Shunhechuanmei Co., Ltd.

MINUTE entry before the Honorable Sara L. Ellis: Pursuant to Plaintiff's notice of voluntary dismissal 19, the Court dismisses this matter without prejudice. Civil case terminated. Emailed notice