2025-cv-04208

COMPLAINT filed by Crye Precision LLC; Filing fee $ 405, receipt number AILNDC-23363019.

Exhibit 1

Exhibit 1

Exhibit 3-1

(Exhibit A)

(Declaration of Kahlia R. Halpern)

(Exhibit A)

Declaration of Madeline B. Halgren

(Exhibit A)

(Exhibit Exhibit)(jumahe sports local,)

(Exhibit Exhibit)(JUMAHE Fashion,)

Exhibit 1

(Exhibit A)

(Exhibit A)

(Exhibit A)

Exhibit 1

(Exhibit 1)

(Exhibit A)

SCHEDULE A by Plaintiff Crye Precision LLC regarding complaint 1 Modified on 5/28/2025.

(Exhibit 2)

(Exhibit 2)

(Exhibit 3-2)

(Exhibit A)

(Exhibit A)

(Exhibit 2)

MOTION by Plaintiff Crye Precision LLC for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Crye Precision LLC

Notice of Claims Involving Trademarks by Crye Precision LLC

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Madeline Halgren

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2). (qrtr,) (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. (qrtr,) (Text entry; no document attached.)

NEW PARTIES: anastos1998, guozhendianzi, hongjunshang, 4.63747E+11, AI FIGHTS, Alsport, ANANc, BaiChuan Outdoors, bang bang kwy, BAULER Mall, Beautiful Awesome Star, BECOME R, Camofla Outdoor, camouflage gear, Carte outdoor Supplies, CVLIFE, dahlia, DAMAI APPAREL, DREAMER LY, East Hill Outdoors, Ercoalgo Original Design, ESDY Factory, ESDY Tactical, FANKE SHEN, Fulai groceries local, GEB ChicParadise, Gebwolf, GENTM, Global Good shop, Gowofly, Hao Yu xiaodian, HGGH, HMYL, Hunters House, Hunting Bag, Hunting Equipments, I Want Adventure travels, Interspace expedition, jishungyp, Jlanfushi, JUMAHE Fashion, jumahe sports local, JUNYEBULUO Outdoor, JURANGOU, Kaheer, LANBAOSI Clothing, Lees Time Shop, Luc outdoor, MAO QIONG, MOZETO, MVPTOO, New fashion mens wear, Outdoor Ye, Primal Pursuit, Qimai Outdoor Equipment, QZTiandi, RODEEL Outdoors, S Snail, Sammyeg, Seven Days shop, Shenzhen Loop Circle Technolog, Sirmedal, Strange Power, sukham yoga, TACEAG Garment, Tactical shop Enthusiasts, Tactical team, TaKino Outdoor, TANSOLE Outdoors, The first area, THYKS, THYKS MM, Top Rattan Factory, TRGPSG FBM, Twinkle Belt, Tymaoyi, UNIONTAC Tactical And Airsoft Gear, UNIONTAC tactical supply, Velany, Vivid Threads, VogueCloset, VOTAGOO GEAR, Water dragon chant packaging, WESSLECO, WI WANG Tactical vest, X hao, Xiao Li OUTDOORS local, XMY CIUM, Yiqifa, Yiyi Yingfang fashion, YUNSUAN OUTDOOR, Zhuangbeiku and L O O G U added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal 3 is granted. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Crye Precision LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Crye Precision LLC in support of motion for temporary restraining order 14

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

DECLARATION of Jonathan E. Antone regarding memorandum in support of motion 15

DECLARATION of Jonathan E. Antone Exhibit 3 - Parts 1-2 regarding declaration 17 Modified on 5/28/2025.

MOTION by Plaintiff Crye Precision LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Crye Precision LLC in support of motion for miscellaneous relief 19

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

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 19, motion for temporary restraining order 14 before Honorable Charles P. Kocoras on 4/29/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for a temporary restraining order 14 and motion for electronic service of process 19 are granted. Enter temporary restraining order. Presentment hearing scheduled on 4/29/2025 is stricken. Mailed notice.

TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 4/22/2025. Mailed notice. Modified on 5/28/2025.

Registry Deposit Information Form by Crye Precision LLC

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

SURETY BOND in the amount of $ 10,000.00 posted by Crye Precision LLC

MOTION by Plaintiff Crye Precision LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Crye Precision LLC in support of extension of time 29

DECLARATION of Kahlia R. Halpern regarding memorandum in support of motion 30

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 29 before Honorable Charles P. Kocoras on 5/6/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to extend the temporary restraining order 29 is granted. The temporary restraining order is extended to May 20, 2025. Presentment hearing scheduled on 5/6/2025 is stricken. Mailed notice.

MOTION by Plaintiff Crye Precision LLC for preliminary injunction

MEMORANDUM by Crye Precision LLC in support of motion for preliminary injunction 34

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 34 before Honorable Charles P. Kocoras on 5/13/2025 at 09:50 AM.

SUMMONS Returned Executed by Crye Precision LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/7/2025, answer due 5/28/2025.

MINUTE entry before the Honorable Charles P. Kocoras: Motion for Preliminary Injunction is granted. The Clerk is directed to unseal Plaintiff's Schedule A to the Complaint 2, Seller Aliases screenshots attached to the Declaration of Jonathan E. Antone 18 and the TRO 24. Plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three (3) business days. Instructions can be found at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Presentment hearing scheduled on 5/13/2025 is stricken. Status report is due on 6/2/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Charles P. Kocoras on 5/12/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

NOTICE of Voluntary Dismissal by Crye Precision LLC as to a Certain Defendant

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 40 and 41 all claims against Defendants listed in the notices, are dismissed without prejudice. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

ATTORNEY Appearance for Defendant Sammyeg by Christopher Paul Keleher

MOTION by Defendant Sammyeg for extension of time to file answer regarding complaint 1 (UNOPPOSED)

NOTICE of Motion by Christopher Paul Keleher for presentment of motion for extension of time to file answer 45 before Honorable Charles P. Kocoras on 6/3/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Defendant Sammyeg's unopposed motion for extension of time 45 is granted; presentment hearing noticed for 6/3/2025 is stricken. Defendant Sammyeg must answer the complaint or otherwise plead by 6/13/2025. Mailed notice.

ATTORNEY Appearance for Defendants JUMAHE Fashion, jumahe sports local by Qin Zhuang

ATTORNEY Appearance for Defendants JUMAHE Fashion, jumahe sports local by Qin Zhuang

MOTION by Defendants JUMAHE Fashion, jumahe sports local for extension of time to file answer regarding complaint 1 probably opposed

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 43 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants JUMAHE Fashion and jumahe sports local's motion for extension of time 50 is granted. Defendants JUMAHE Fashion and jumahe sports local must answer the complaint or otherwise plead by 6/28/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 53 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

ATTORNEY Appearance for Defendants CVLIFE, Primal Pursuit by Bole Yuan

MOTION by Defendants CVLIFE, Primal Pursuit for extension of time to file answer Unopposed

MINUTE entry before the Honorable Charles P. Kocoras: Defendants CVLIFE and Primal Pursuit's unopposed motion for extension of time 56 is granted. Defendants CVLIFE and Primal Pursuit must answer the complaint or otherwise plead by 6/18/2025. Mailed notice.

STATUS Report pursuant to 38 by Crye Precision LLC

MINUTE entry before the Honorable Charles P. Kocoras: The Court reviewed Plaintiff's status report 58. An updated status report is due on 7/2/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 60 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 62 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Andrew Daniel Burnham

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 64 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

Liu Guoqiang ANSWER to Complaint 25-cv-04028 by jumahe sports local

Liu Bin ANSWER to Complaint 25-cv-04028 by JUMAHE Fashion

MOTION by Attorney Qin Zhuang to withdraw as attorney for JUMAHE Fashion, jumahe sports local. New address information: Liu Guoqiang& Liu Bin, No.92, Yunshan Street, Baigou New Town, Baoding City, Hebei Province, 074000, P.R. China, 0086-195-2034-8085

MOTION by Plaintiff Crye Precision LLC to strike answer to complaint 67, answer to complaint 68

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion to strike 70 before Honorable Charles P. Kocoras on 7/1/2025 at 09:50 AM.

ATTORNEY Appearance for Defendant TRGPSG FBM by Timothy Tiewei Wang

MOTION by Defendant TRGPSG FBM for extension of time to file answer regarding complaint 1 Unopposed

MINUTE entry before the Honorable Charles P. Kocoras: Defendant TRGPSG's unopposed motion for extension of time 73 is granted. Defendant TRGPSG must answer the complaint or otherwise plead by 7/15/2025. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Defendant's motion to withdraw as attorney 69 is granted, Attorney Qin Zhuang is terminated. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to strike 70 is granted. The answers and affirmative defenses filed by Defendants JUMAHE Fashion 68 and Defendant jumahe sports local 67 are stricken. Defendants appear to be business entities no longer represented by counsel, and "[a] corporation is not permitted to litigate in a federal court unless it is represented by a lawyer licensed to practice in that court." United States v. Hagerman, 545 F.3d 579, 581 (7th Cir. 2008); see also In re IFC Credit Corp., 663 F.3d 315, 318 (7th Cir. 2011) ("Corporations unlike human beings are not permitted to litigate pro se."). "This rule applies even if the corporation is owned by only a few closely related individuals or by a single person who seeks to appear on behalf of the corporation." United States v. Certain Real Prop., 381 F. Supp. 3d 1007, 1008 (E.D. Wis. 2018). Defendants JUMAHE Fashion and jumahe sports local are granted until 7/15/2025 to find an attorney to appear on their behalf and file new answers to Plaintiff's complaint. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 77 all claims against Defendants listed in the notice, are dismissed without prejudice.

STATUS Report Pursuant to 59 by Crye Precision LLC

MINUTE entry before the Honorable Charles P. Kocoras: The Court reviewed Plaintiff's status report 79. An updated report is due on 8/1/2025. Mailed notice.

ATTORNEY Appearance for Defendants JUMAHE Fashion, jumahe sports local by Weilian Song

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 82 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

ANSWER to Complaint by JUMAHE Fashion, jumahe sports local

NOTICE of Voluntary Dismissal by Crye Precision LLC as to a certain Defendant

MOTION by Plaintiff Crye Precision LLC for entry of default, MOTION by Plaintiff Crye Precision LLC for default judgment as to Certain Defendants

MEMORANDUM by Crye Precision LLC in support of motion for entry of default, motion for default judgment 86

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 87

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for entry of default, motion for default judgment 86 before Honorable Charles P. Kocoras on 7/29/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 85 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for entry of default and default judgment 86 is granted. Enter Final Judgment Order. Presentment hearing scheduled on 7/29/2025 is stricken. Civil Case Terminated. Mailed notice. Modified on 7/28/2025.

DEFAULT Judgment Order. Signed by the Honorable Charles P. Kocoras on 7/28/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding Default Judgment, order 92 in the amount of $300,000 as to certain defendants

MAILED trademark report with certified minute order dated 7/28/2025 to Patent Trademark Office, Alexandria VA. (jn,)

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal 95 all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.