2025-cv-04221

COMPLAINT filed by GJL Holding Company LLC; Filing fee $ 405, receipt number AILNDC-23364106.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff GJL Holding Company LLC Schedule A to Complaint [1]

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Christopher Romero

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff GJL Holding Company LLC by Yi Bu

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by GJL Holding Company LLC

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,)

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

MINUTE entry before the Honorable John Robert Blakey: Plaintiff has filed a complaint seeking to sue 97 separate defendants for infringement of six different copyrights. See 1, 2. But joinder of multiple defendants in a single copyright infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). Here, Plaintiff's complaint lumps all Defendants together and alleges global infringement of all claimed copyrights; presumably to support joinder, Plaintiff alleges, in a conclusory manner, that the Defendants "share unique identifiers, such as design elements and similarities of the unauthorized products offered for sale, establishing a logical relationship between them and suggesting that Defendants' illegal operations arise out of the same transaction, occurrence, or series of transactions or occurrences." 1 at 7, 10, 14. But the conclusion does not necessarily follow the alleged facts; it is equally possible that each online retailer set up shop in the same or similar manner. See, e.g., Estee Lauder Cosms. Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182, 188-89 (N.D. Ill. 2020). Plaintiff also alleges that "the Infringing Products for sale in the Defendant Internet Stores bear similarities and indicia of being related to one another, suggesting that the Infringing Products were manufactured by and come from a common source and that, upon information and belief, Defendants are interrelated." Id. 31. This allegation remains conclusory and unsupported, and the Court need not accept it. As a result, the Court finds that Plaintiff has failed to allege facts to support the joinder of all 97 Defendants in this case and thus dismisses the complaint 1 without prejudice. If Plaintiff can, consistent with its obligations under Rule 11, amend its pleading to allege facts to support joinder, it may do so by 5/9/25. If Plaintiff elects to amend, it should also bolster its allegations concerning personal jurisdiction as to each Defendant. Plaintiff alleges that "this Court may properly exercise personal jurisdiction over Defendants since each of the Defendants directly targets consumers in the United States, including Illinois, through at least the fully interactive commercial internet stores operating under the Defendant aliases and/or the online marketplace accounts identified in Schedule A attached hereto." 1 2. But the mere maintenance of a website accessible in Illinois remains insufficient to confer personal jurisdiction. See, e.g., Am. Bridal & Prom Indus. Ass'n, Inc. v. The Partnerships & Unincorporated Associations Identified on Schedule A, 192 F. Supp. 3d 924, 93435 (N.D. Ill. 2016) (simply alleging the existence of purported counterfeiting via an interactive website is not enough, by itself, to confer personal jurisdiction); Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796, 803 (7th Cir. 2014) ("Having an interactive website. should not open a defendant up to personal jurisdiction in every spot on the planet where that interactive website is accessible."); Rubik's Brand, Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 20-CV-5338, 2021 WL 825668, at *3 (N.D. Ill. Mar. 4, 2021) (screenshot evidence showing that an order could be placed by an Illinoisan, "amounts to nothing more than maintaining an interactive website that is accessible in Illinois," and "that alone cannot confer personal jurisdiction."). If Plaintiff declines to amend, the Court will dismiss this case. Mailed notice.

MAILED Copyright report to Registrar, Washington DC.

((List of Copyrights))

AMENDED complaint by GJL Holding Company LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

(Exhibit 1)

Amended Schedule A to Complaint 1, Schedule A 2 and Amended Complaint 14 by GJL Holding Company LLC

MEMORANDUM in Support of 16 Exparte Motion

Exhibit 1

Declaration of Keith A. Vogt

(Exhibit 1-2, of Keith A. Vogt's Declaration)

Presentment for Exparte Motion 16 NOTICE of Motion by Keith A. Vogt for presentment of before Honorable John Robert Blakey on 5/14/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: On 4/18/25, this Court dismissed Plaintiff's complaint because it failed to support the joinder of all 97 named defendants in a single suit, see [12]. Plaintiff has now filed an amended complaint, which names just one Defendant, see [14], [15], and thus avoids any joinder issues. Plaintiff may thus proceed on its amended complaint [14]. Additionally, based upon Plaintiff's submissions, the Court grants Plaintiff's motion for leave to conduct expedited discovery and for electronic service of process [16]. The 5/14/25 Notice of Motion date is stricken. Mailed notice.

ORDER for Leave to Conduct Expedited Discovery and Service of Process by E-mail and/or Electronic Publication. Signed by the Honorable John Robert Blakey on 5/13/2025. Mailed notice.

SUMMONS Submitted (Court Participant) for defendant(s) IPOO. by Plaintiff GJL Holding Company LLC

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

SUMMONS Returned Executed by GJL Holding Company LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/21/2025, answer due 6/11/2025.

(Declaration of Service, Keith A. Vogt)

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 1 IPOO

MINUTE entry before the Honorable John Robert Blakey: By notice of voluntary dismissal, 24, this case is dismissed as to Defendant IPOO (Def. No. 1) without prejudice under Rule 41(a). The Court strikes all set dates and deadlines. All matters in this case having now been disposed, the case is terminated. Mailed notice.