2025-cv-04961

COMPLAINT filed by Leatherman Tool Group, Inc.; Filing fee $ 405, receipt number AILNDC-23445049.

Exhibit 1

SEALED EXHIBIT by Plaintiff Leatherman Tool Group, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Leatherman Tool Group, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Leatherman Tool Group, Inc.

Notice of Claims Involving Trademarks by Leatherman Tool Group, Inc.

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Madeline Halgren

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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: A1BCBB7YQ3O0JP, aimaiyou, bangonghudianzishangwu, chenhaiyan SHOP, FenYangShiWeiChengShangMaoYouXianGongSi, GauYan, hezhiZhangYin, houjiangshan111, jie De, jutianixiacai, liang1515, Longkeshangmaodian, moyanyingSHOP, uhomu955, VKtoma, xiamenshiyuwancumiandianzishangwuyouxiangongsi, yanxilai, yuczw, zhengyi998, zhuhaishixiqimaoyizhongxin, F&X MALL, Happy Winter 2025, Kai Sheng, LaboteSI, wang gang and zongheng added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(List of Trademarks, Ex. 1)

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

MOTION by Plaintiff Leatherman Tool Group, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Doug Anderson regarding memorandum in support of motion[14]

Exhibit 1

SEALED EXHIBIT by Plaintiff Leatherman Tool Group, Inc. Exhibit 2 regarding declaration[16]

MOTION by Plaintiff Leatherman Tool Group, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief[18], motion for temporary restraining order[13], motion for leave to file[3] before Honorable Jorge L. Alonso on 5/14/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [13] [18] 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 $26,000--$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 5/14/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 5/14/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Leatherman Tool Group, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Leatherman Tool Group, Inc.

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

SURETY BOND in the amount of $ 26,000.00 posted by Leatherman Tool Group, Inc.

MOTION by Plaintiff Leatherman Tool Group, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for preliminary injunction[27]

Declaration of Kahlia R. Halpern

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[27] before Honorable Jorge L. Alonso on 5/27/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Leatherman Tool Group, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/21/2025, answer due 6/11/2025.

Declaration of Madeline B. Halgren

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 5/27/25 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 [27] 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 6/26/25 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 5/27/2025. Notice mailed by Judge's staff

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Rachel S Miller

MOTION by Plaintiff Leatherman Tool Group, Inc. for entry of default, MOTION by Plaintiff Leatherman Tool Group, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Leatherman Tool Group, Inc. in support of motion for entry of default, motion for default judgment[36]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[37]

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment[36] before Honorable Jorge L. Alonso on 6/24/2025 at 09:30 AM.

Exhibit A

MOTION by Defendant LaboteSI for extension of time. (Received by online pro se portal on 6/20/25).

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion 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

ATTORNEY Appearance for Plaintiff Leatherman Tool Group, Inc. by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's oral motion to strike Defendant LaboteSI's Motion for extension [40] is granted. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants [36] is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/24/2025. Notice mailed by Judge's staff

FULL SATISFACTION of Judgment regarding order 44 in the amount of $200,000 as to certain defendant