2025-cv-04553

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 405, receipt number AILNDC-23401456.

Exhibit 1

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

Notice of Claims Involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Rachel Meira Ackerman

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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: A3K62ECS06K36H, chenlonghui SHOP, dengpandianzi, HomiTunky, Hraewgra, huangningwanju, jiningkexin, jininglezhixin, Jiolelores, juyexiangnan, KGDKEIJ STORE, meishan, pingnanxianyanghuaqingdianzishangwujingyingbu, SNLans, Vanda us, Yikang2024, YInan_doNG, YongDeBaoZhanJingShangMaoYouXianGongSi, zhenganqingriyongbaihuodianpu, ZX DRAGON LLC, bang-9226, goldasia79, AFMaisonue, BBA ZZQ, beautiful disaster, Beautymo, Chi Jin Arts and Crafts, Cloud painting shop, Cocomized, CUSMASTER local, Decorative Painting Factory gao, Decorative painting W, DELAQ, Dimensional Things, DQQDsss, Dreamswemake, DSDTWOE, DWVirgoJYX, Elegant Home Finds, Excelente tienda de pintura, Family Aritist, Fat Planet, FG Art shop, Fit Fabric, Frame prosperity B, GlintcartA, HappyyTime, Helen QWE, Hemingtonge, Hemitong, Hemitongk, Hemitongl, HIASOF, Honglong cultural L, Ideal Cup, ImaginarySpace, IUDDIWEJKDC, LGoilcatw, lin Decorative Painting four, lin decorative painting two, love diy zc, Love Never Fades Poster, lsmoto, LWHLWH, LX art and life, Mac KLM, MadeWithLoveHub, Metal Wall Shop, MISS FJJ, MISS WM, MMKDS, Mrlihualitwo, New User VIP Channel, Only Family, Oxygen bus, Qiteprints local, Retro Western Cowboy, SoSo Happy, Sparkling Cups, The elderly and the sea, The Ideal Cup, tianqing poster, Tin Label I, Tinners Stew, TK Easel Essence, TLYI SHOP, TMArt family, TTTCASE, Unique mens house clothing, Visual Delights, VS Shop, Weekend Outdoor, Y Elaborate decoration, yhalk wholesale goods, YING D Fashion Decorative Painting A, Yiyaxuan Clothing Co Ltd, zhuo yi han tin signs A, zuyi d, guangzhoujunxinganjiefuwuyouxiangongsi, hangzhouhezukeji and Liyong.LTD added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

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

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for temporary restraining order[14]

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

DECLARATION of Adraea M. Brown regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 2 Parts 1-3 regarding declaration[17]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, Inc. 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 temporary restraining order[14], motion for miscellaneous relief[19] before Honorable Charles P. Kocoras on 5/6/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for electronic service of process [19] and motion for a temporary restraining order [14] are granted. Enter Temporary Restraining Order. Presentment hearing scheduled on 5/6/2025 is stricken. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Charles P. Kocoras on 5/1/2025.Mailed notice.

Registry Deposit Information Form by Harley-Davidson Motor Company, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Harley-Davidson Motor Company, Inc.

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 Harley-Davidson Motor Company, Inc.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Jeremy C. Daniel for all further proceedings pursuant to 28:294(b). Mailed notice

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction[30]

Declaration of Marcella D. Slay

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for preliminary injunction[30] before Honorable Jeremy C. Daniel on 5/15/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/12/2025, answer due 6/2/2025.

Declaration of Rachel M. Ackerman

Exhibit A

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Berel Yonathan Lakovitsky

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 5/15/2025. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction 30 is granted in part. The motion is denied as to the following relief: (1) the Court makes no findings concerning personal jurisdiction because that issue has not been litigated in this case; (2) for the reasons stated on the record and in this minute order, the Court declines to extend all of the relief previously granted in the temporary restraining order; (3) the plaintiff has failed to provide good cause to establish seven day response times for third-parties or three-day response times for the defendants, therefore, the Court sets response times at fourteen days; (4) the requested asset restraint of "any money or other of Defendants' assets" is too broad, therefore the Court limits any asset restraint to "money or assets traceable to sales of the accused products;" (5) the plaintiff has not named any third-parties as defendants, nor has the plaintiff shown any third-parties to be "in active concert or participation" with the defendants, therefore the Court will not order third parties to disable or cease displaying any advertisements used by the defendants; and (6) the Court increases the bond from $10,000 to $72,000, which is the amount of money the plaintiff represented as currently restrained. The plaintiff is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on court's website located www.ilnd.uscourts.gov/instructions. Mailed notice.

SURETY BOND in the amount of $ 72,000.00 posted by Harley-Davidson Motor Company, Inc.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendant

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, 41

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 42

(Exhibit 1)

NOTICE of Motion by Marcella Deshonda Slay for presentment of motion for entry of default, motion for default judgment, 41 before Honorable Jeremy C. Daniel on 6/18/2025 at 09:30 AM.

(Exhibit A)

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Plaintiff's motion for entry of default judgment [41] is taken under advisement. Plaintiff's supplement to the motion is due on or before 7/9/2025. Court will rule by mail. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

TRANSCRIPT OF PROCEEDINGS held on 06-18-2025 before the Honorable Jeremy C. Daniel. Order Number: 52198. Court Reporter Contact Information: Krista Burgeson, krista_burgeson@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 7/22/2025. Redacted Transcript Deadline set for 8/1/2025. Release of Transcript Restriction set for 9/29/2025.

Plaintiff's Supplemental Brief in Support of its Motion for Entry of Default and Default Judgment as to all remaining Defendants pursuant to 45 by Harley-Davidson Motor Company, Inc.

(Exhibit A)

DECLARATION of Marcella D. Slay regarding other 49

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 6)

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 5 regarding declaration 50

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 8/11/2025. The plaintiff's motion for default judgment [41] is granted. Civil case terminated. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA

Full SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, terminated case[52] in the amount of $50,000 as to certain defendants