2025-cv-04695

COMPLAINT filed by Revelyst Operations LLC ; Filing fee $ 405, receipt number AILNDC-23416157.

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

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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: combine-d, cosmoing2020, digital2018, e4trading333, flame2024, fsbzc2088, ha-cn14, levii821, liyuxuan88 and longlived28 added to case caption.

NEW PARTIES: oneworld327, Optical-Fire, wers1245, yesoned and yoyo19850912 added to case caption.

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for leave to file under seal 4 is granted. Schedule A to the complaint 3, filed provisionally under seal, may remain under seal. By 5/8/2025, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Peter Krusiewicz

PLAINTIFF'S DISCLOSURE OF PRIOR CASES by Revelyst Operations LLC

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 --

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for a temporary restraining order 10 is taken under advisement. By 5/15/2025, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) an index that matches each defendant to the screenshots supplied in support of the motion, lists the dates those screenshots were taken, and identifies, on a defendant-by-defendant basis, the specific trademarks each defendant has allegedly infringed. Mailed notice

SUPPLEMENT to order on motion for temporary restraining order, set motion and R&R deadlines/hearings, 16 - supplemental disclosure -

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC -- Ex. 1 to supplement - comparison chart with additional information -- regarding supplement 17

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 10 is granted. Plaintiff's motion for expedited discovery and electronic service 14 is also granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 5/13/2025. Mailed notice

REGISTRY Deposit Information Form by Revelyst Operations LLC (Received at the Intake Counter on 05/14/25.)

SURETY BOND in the amount of $ 45,000.00 posted by Revelyst Operations LLC

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

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order 23 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 5/22/2025. Mailed notice

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)

MOTION by Plaintiff Revelyst Operations LLC for preliminary injunction

(Unpublished)

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

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 30 is taken under advisement. Any objection or response is due before 6/9/2025. Upon review of the declaration of service, the Court directs the plaintiff, by 6/1/2025, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 6/9/2025. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 31, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 8, 40, and 43 are dismissed from this case. Mailed notice

CERTIFICATE of Service by Plaintiff Revelyst Operations LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, 32

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 35, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 4, 11, 14, 37, 44, and 48 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon review of the certificate of service 34, the plaintiff is directed to file a supplement identifying what email addresses it has used to serve the defendants. Mailed notice

SUPPLEMENT to text entry 37, certificate of service 34 SUPPLEMENT TO CERTIFICATE OF SERVICE [DKT. 34]

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

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction 30 is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 6/18/2025 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 6/16/2025. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 1, 2, 5, 7, 9, 10, 12, 13, 15, 16, 18, 20, 33, 35, 46, 47, and 49 are dismissed from this case. Mailed notice

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

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 43, and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant nos. 3, 21, 24, 32, and 42 are dismissed from this case. Mailed notice

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

MEMORANDUM by Revelyst Operations LLC in support of motion for default judgment[45] 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 - 25-cv-04431

Other Unpublished

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 45 is taken under advisement. Any objections or responses are due by 7/21/2025. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 7/12/2025. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Peter Krusiewicz on behalf of Revelyst Operations LLC regarding order on motion for default judgment, set motion and R&R deadlines/hearings, 47

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 45 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 7/23/2025. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA.