2025-cv-04431

COMPLAINT filed by Revelyst Operations LLC ; Filing fee $ 405, receipt number AILNDC-23389647.

Exhibit 1 - TM Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC - Schedule A to Complaint - regarding complaint, 1

MOTION by Plaintiff Revelyst Operations LLC to seal document exhibit 3

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Revelyst Operations LLC

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Matthew A. Werber

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(List of Trademarks, Ex. 1)

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Peter Krusiewicz

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2).

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.

NEW PARTIES: 2daf-9256, 7ozbargain, aatemeow2, ameiz5w, asdf--5, costysh, eric230518, forevertopstore, greenbase-hk, hardwaregood, hgty2019 and hmsaerge added to case caption.

NEW PARTIES: home-dropgo, industrialmachine5, jiangbi_22, liang4-2250, limagicq, meiswoor715, mutina0715, oursport888, pbis9567, smarteasylife, superplaza-07, tianyigeltd and topteng-11 added to case caption.

NEW PARTIES: trucipor, vastfire-light, xfcz567, yqs120xiong, zslingup8, annewhd, bicycle-light, e-bojo, e1dao2bin33, easymart2016-8, eforshop-04, focalbuying and is_sophie added to case caption.

NEW PARTIES: jiaozhi-222, landa816, litieqi2016_9, magotactical, oscarsport8, sgnightvision, SPECPRECISION, u111san3, wstopseller and gogofastphones added to case caption.

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

MOTION by Plaintiff Revelyst Operations LLC for temporary restraining order PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

MEMORANDUM by Revelyst Operations LLC in support of motion for temporary restraining order 10 MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

Declaration of Paul Mills

Declaration of Matthew Werber

(Unpublished)

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT 1 TO THE DECLARATION OF PAUL MILLS (SEALED) regarding memorandum in support of motion, 11

Exhibit 1 - Part 1 of 2

(Exhibit 1- Part 2 of 2)

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT A TO THE DECLARATION OF MATTHEW A. WERBER (SEALED) regarding memorandum in support of motion, 11

(Exhibit A)

MOTION by Plaintiff Revelyst Operations LLC FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE

Declaration of Matthew Werber

Exhibit A - to the Declaration of Matt Werber

Exhibit B - to the Declaration of Matt Werber

(Unpublished)

MEMORANDUM by Revelyst Operations LLC -- MEMORANDUM ON JOINDER --

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief, 14, motion for temporary restraining order 10 before Honorable Jorge L. Alonso on 4/30/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 4 10 14 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $49,000--$1,000 per defendant--is sufficient to secure the injunctive relief. Motion hearing set for 4/30/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/29/2025. Notice mailed by Judge's staff notice

SURETY BOND in the amount of $ 49,000.00 posted by Revelyst Operations LLC. (Document not imaged)

MOTION by Plaintiff Revelyst Operations LLC, PLAINTIFF'S MOTION TO EXTEND TEMPORARY RESTRAINING ORDER

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief 20 before Honorable Jorge L. Alonso on 5/13/2025 at 09:30 AM.

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

SUMMONS Returned Executed by Revelyst Operations LLC as to All Defendants.

(Declaration)

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion to extend temporary restraining order 20 is granted. The temporary restraining order is extended for 14 days to 5/27/25. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Motion hearing date of 5/13/25 is stricken. Notice mailed by Judge's staff

MOTION by Plaintiff Revelyst Operations LLC for preliminary injunction

(Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion for preliminary injunction 26 before Honorable Jorge L. Alonso on 5/22/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/22/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [26] is granted. Enter Preliminary Injunction Order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Telephonic status hearing set for 6/24/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jorge L. Alonso on 5/22/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MOTION by Plaintiff Revelyst Operations LLC for default judgment as to - Defaulting Defendants -

MEMORANDUM by Revelyst Operations LLC in support of motion for miscellaneous relief[33] MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMENT

Exhibit A - Defaulting Defendants

Declaration of Matt Werber

Unpublished - Spin Master

Other Unpublished Cases

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief[33] before Honorable Jorge L. Alonso on 6/11/2025 at 09:30 AM.

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to certain defendants

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 6/11/25 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment 33 is granted. Enter default judgment order. Notice mailed by Judge's staff

DEFAULT Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/11/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic Status hearing held. The remaining Defendants have been dismissed from this case. Civil case terminated. Notice mailed by Judge's staff

ORDER Granting Plaintiff's Motion For Release Of Surety Bond. Signed by the Honorable Jorge L. Alonso on 6/25/2025. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants