2025-cv-04225

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23364745.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

Exhibit 4 to the Complaint

Exhibit 5 to the Complaint

Exhibit 6 to the Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Complaint for Copyright Infringement regarding complaint, [1]

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal

Declaration of Katherine M. Kuhn in Support of Motion to Seal

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [3]

(Exhibit 2 to the Declaration of K. Kuhn)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

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: Guangzhou Outpace Sportswear Co., Ltd., Dongguan Tianchen Garment Technology Co., Ltd. and Shenzhen Longgang Yunna E-Commerce Firm added to case caption.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Hong Kong Leyuzhen Technology Co. Limited to Bayramoglu Law Offices LLC 1540 West Warm Springs Road Suite 100 Henderson, NV 89014 via certified mail # 9589 0710 5270 0579 7840 63.

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

MAILED Copyright report to Registrar, Washington DC

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and ELECTRONIC SERVICE OF PROCESS PURSUANT TO FRCP 4(f)(3)

MEMORANDUM IN SUPPORT OF MOTION FOR ELECTRONIC SERVICE OF PROCESS

Declaration of K. Kuhn in Support of Motion for Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages IN SUPPORT OF PLAINTIFFS MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order AND EXPEDITED DISCOVERY

MEMORANDUM IN SUPPORT OF PLAINTIFFS EX PARTE MOTION FOR ENTRY OF A TEMPORARY RE

Declaration of K. Kuhn in Support of Motion forTemporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of L. Li in Support of Motion for Temporary Restraining Order

NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for leave to file excess pages[14], motion for service by publication, [13], motion for temporary restraining order, [15] 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 electronic service of process [13], motion to file excess pages [14] and motion for temporary restraining order [15] are granted. Enter temporary restraining order. Presentment hearing scheduled on 4/29/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 4/25/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified in Schedule A Hereto by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

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

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time First Request to Extend Temporary Restraining Order

Exhibit Memorandum in Support of First Motion to Extend Temporary Restraining Or

Declaration of Joseph W. Droter in Support of Motion to Extend Temporary Restrai

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [21] before Honorable Charles P. Kocoras on 5/13/2025 at 09:50 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to extend the temporary restraining order 21 and motion to deposit funds into the Court's registry 23 are granted. The temporary restraining order is extended to 5/23/2025. Presentment hearing scheduled on 5/13/2025 is stricken. Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for extension of time Second Motion to Extend Temporary Restraining Order

Exhibit Memorandum in Support of Second Motion to Extend Temporary Restraining O

Declaration of Katherine M. Kuhn in Support of Second Motion to Extend

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of extension of time, [26] before Honorable Charles P. Kocoras on 5/27/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to extend the temporary restraining order [26] is granted. The temporary restraining order is extended to 6/6/2025. Presentment hearing scheduled on 5/27/2025 is stricken. Mailed notice.

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/27/2025, answer due 6/17/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

Exhibit Memorandum in Support of Motion for Preliminary Injunction

Declaration of Joseph W. Droter in Support of Motion for Preliminary Injunction

Exhibit 1 to the Declaration of J. Droter

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [30] before Honorable Charles P. Kocoras on 6/3/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for preliminary injunction [30] is entered and taken under advisement. Court will rule by mail. Presentment hearing scheduled on 6/3/2025 is stricken. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Motion for Preliminary Injunction is granted. The Clerk is directed to unseal Plaintiff's sealed exhibit [2] and [4], and the temporary restraining order [18]. 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. Status report is due on 6/26/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Charles P. Kocoras on 6/5/2025. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 3 Defendants

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Joseph W. Droter in Support of Motion for Default and Default Jud

Exhibit 1 to the Declaration of J. Droter

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [35] before Honorable Charles P. Kocoras on 7/1/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for entry of default and default judgment [35] is granted. Enter Final Default Judgment Order. Presentment hearing scheduled 7/1/2025 is stricken. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 6/25/2025. Mailed notice.

MAILED copyright report with order dated 6/25/2025 to Registrar, Washington DC

MAILED copyright report with order dated 6/25/2025 to Registrar, Washington DC

NOTICE of Correction regarding [39]