2025-cv-04212

COMPLAINT filed by Lucio and Meera Santoro T/A Santoro Licensing; Filing fee $ 405, receipt number AILNDC-23363517.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing Schedule A regarding complaint[1]

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lucio and Meera Santoro T/A Santoro Licensing

Notice of Claims Involving Trademarks by Lucio and Meera Santoro T/A Santoro Licensing

ATTORNEY Appearance for Plaintiff Lucio and Meera Santoro T/A Santoro Licensing by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Lucio and Meera Santoro T/A Santoro Licensing by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Lucio and Meera Santoro T/A Santoro Licensing by Alexander Whang

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2). (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,)

NEW PARTIES: Shenzhen Huachuang Zhilian Technology Co., Ltd., Shenzhen Shenman Technology Co., Ltd, Shenzhen Shenman Technology Co., Ltd., AliEx Preess Z034 Store Store, BBTHBDNBY Cuhebjvl Store, Beautiful Bag Vip Store, Custom Sheet Set Store, Customized Flag Store, Design Cushion Cover Store, Enjoy A Better Life Store, Funny Bags Store, Gold Medal Clothing Factory Store Store, Great Value Store, Haute Couture Phone Case Store, L JHYDFCNB Art 3C 306 Store, Lucky27 Store, Mai Bao Ren Store, Manual Art Outlet Stores Store, NBDRUICAI NBDRUICAI Fashion 347 3C Store Store, NBDRUICAI Retro 348 3C Store Store, Shop1102323223 Store, Shop1103211119 Store, Shop1103646144 Store, Shop1103802020 Store, Soft Cloud Store, Stars Customized DIY-117 Store, VIP Custom Poster Decoration-96 Store, BABAITE ALILI 17 Store, Beauty CF Z029 Store, Digitialing Store, Disney Square Diamond Painting Store, HEARMNY July Store, Hot Ran 119 Store, Kpop-Classic Clothes Store, lili baby house Store, LJHYDFCNB Kawaii 3c 349 Store, Luyizebb2019 Store, Printed Girls Underwear Store, QUANYIBAI ALILI PC34 Store, RICHPLUS Store, Shop1102373259 Store, Shop1102904194 Store, Shop1102958801 Store, Shop1103070084 Store, Shop1103272594 Store, Shop1103332497 Store, YUNIAN3 ALILI PC31 Store, YWHZX19 Textile Store, YY-122 Store, DUCHUY96, sherateen, ERIOYIO, Funny Kitty Shirts and LYNDZGS added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Lucio and Meera Santoro T/A Santoro Licensing to Attorney Martin Francis Trainer (TME Law, P.C.) 10 S. Riverside Plaza, Suite 875 Chicago, IL 60606 certified mail #9589 0710 5270 0579 7833 49

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Lucio and Meera Santoro T/A Santoro Licensing in support of motion for miscellaneous relief 11

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 12

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing Exhibit 2, Parts 1-3 regarding declaration 13

Exhibit 2, Part 1

Exhibit 2, Part 2

(Exhibit 2, Part 3)

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Lucio and Meera Santoro T/A Santoro Licensing in support of motion for miscellaneous relief 15

Declaration of Martin F. Trainor

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 15, motion for miscellaneous relief 11, motion for miscellaneous relief 3 before Honorable Elaine E. Bucklo on 4/25/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file certain documents under seal [3]; Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint and expedited discovery [11]; and Plaintiff's motion for electronic service of process pursuant to FED. R. CIV. P. 4(f)(3) [15] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 6/11/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 6/4/2025. Law TME Law, P.C. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 7/14/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 7/7/2025, plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 5/28/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A" by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing

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

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing to Extend the Temporary Restraining Order

MEMORANDUM by Lucio and Meera Santoro T/A Santoro Licensing in support of motion for miscellaneous relief[22]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[22] before Honorable Elaine E. Bucklo on 6/11/2025 at 09:45 AM.

CIVIL BOND in the amount of $ 10,000 posted by Lucio and Meera Santoro T/A Santoro Licensing. (Document not Scanned).

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Ex Parte motion to extend the temporary restraining order [22] is granted to 6/25/2025. Mailed notice.

SUMMONS Returned Executed by Lucio and Meera Santoro T/A Santoro Licensing as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 6/20/2025, answer due 7/11/2025.

Declaration of Sydney Fenton

Exhibit A

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for preliminary injunction

Exhibit A

MEMORANDUM by Lucio and Meera Santoro T/A Santoro Licensing in support of motion for preliminary injunction[28]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[28] before Honorable Elaine E. Bucklo on 6/25/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of preliminary injunction [28] is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Paul Varley [14], and the TRO [19]. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 6/24/2025. Mailed notice.

STATUS Report by Lucio and Meera Santoro T/A Santoro Licensing

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff is engaged in active settlement negotiations with multiple defendants. Status hearing is reset for 9/11/2025 at 9:45 a.m. (to track the case only; no appearance required). The plaintiff shall file a written status report by 9/4/2025. The court will enter an order in response to the status report. Mailed notice.

MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for entry of default, MOTION by Plaintiff Lucio and Meera Santoro T/A Santoro Licensing for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Lucio and Meera Santoro T/A Santoro Licensing in support of motion for entry of default, motion for default judgment, [35]

Exhibit 1

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[36]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, [35] before Honorable Elaine E. Bucklo on 9/11/2025 at 09:45 AM.

STATUS Report by Lucio and Meera Santoro T/A Santoro Licensing

Exhibit A

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the plaintiff's status report. Plaintiff's motion for entry of default and default judgment [35] against all defendants remaining in this case is granted. Enter Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff or Plaintiff's counsel, TME Law P.C. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 9/11/2025. Mailed notice.

FULL SATISFACTION of Judgment as to a certain defendant