2025-cv-05251

COMPLAINT filed by The Gillette Company LLC ; Filing fee $ 405, receipt number AILNDC-23474652.

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SEALED EXHIBIT by Plaintiff The Gillette Company LLC Schedule A regarding complaint, [1]

MOTION by Plaintiff The Gillette Company LLC for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

Notice of Claims Involving Trademarks by The Gillette Company LLC

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Gillette Company LLC

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Alexander Whang

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.

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 2).

NEW PARTIES: Guizhou Nine Fun Technology Co., Ltd., Flower Cat Store, Grandpa Beard Store, Hello Sir Store, jifuli Razor Official Store, Laile Home Store, Super--Man Store, ZHELU Fashion & Decoration Home Store, GONGSUNYANG, LanHai zhengd, Longnisong, ruichida, Sakura LI, Silent -LLC, YiBaiMiao, YSAUQEIQ, Zhangzojlld, ZhengZhouTongYuZhengJiDianSheBeiYouXianGongSi, zhouyannaxiaodian, pang04, abqluggage.live, electronicnests, geranium-78, homeandgarden-only, jinla-4084, kashmall, onbuy888, outdoorsyessentials, qingyabazaar, sophia384, sunsuns-9676, youbeixin06, Shen Zhen Shi De Rui Kai Ke Ji You Xian Gong Si, PANRICH, Sheiny, szrz and walokstore added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for leave to file under seal [3] is granted. By 5/20/25, 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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(List of Trademarks, Ex. 1)

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

RESPONSE by Plaintiff The Gillette Company LLC to order on motion for miscellaneous relief, terminate motions, [10]

MOTION by Plaintiff The Gillette Company LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by The Gillette Company LLC in support of motion for miscellaneous relief[14]

Declaration of Martin F. Trainor

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DECLARATION of David Upite regarding memorandum in support of motion[15]

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SEALED EXHIBIT by Plaintiff The Gillette Company LLC Exhibit 2, Parts 1-4 regarding declaration[16]

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(Exhibit 2, Part 4)

MOTION by Plaintiff The Gillette Company LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by The Gillette Company LLC in support of motion for miscellaneous relief[18]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for electronic service of process 18 is granted. The plaintiff's motion for a temporary restraining order 14 is taken under advisement. By 5/23/25, 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 [14] by The Gillette Company LLC

Exhibit 1

MINUTE entry before the Honorable John J. Tharp, Jr: Upon review of the supplemental index, the screenshots do not show a single trademark that was allegedly infringed by each of the defendants listed in the plaintiff's Schedule A, raising a question as to the propriety of joinder. Plaintiff is directed to supplement the TRO motion with a brief explaining why joinder is proper notwithstanding the lack of a single trademark common to all defendants. (In other words, the brief should explain why joinder of claims of infringement of different trademarks is appropriate in this case.) If the brief contains new screenshots, those screenshots must be included in an updated version of the certification and index attached to Plaintiff's TRO motion. Alternatively, the plaintiff may amend its complaint to include only defendants alleged to have violated the same trademark and file a renewed motion for entry of a TRO. Mailed notice

AMENDED complaint by The Gillette Company LLC against The Partnerships And Unincorporated Associations Identified On Schedule A

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SEALED EXHIBIT by Plaintiff The Gillette Company LLC Schedule A regarding amended complaint, [23]

MOTION by Plaintiff The Gillette Company LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery, Renewed

SEALED EXHIBIT by Plaintiff The Gillette Company LLC regarding declaration[16]

MOTION by Plaintiff The Gillette Company LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery, Renewed (CORRECTED)

SUPPLEMENT to motion for miscellaneous relief[27]

SEALED EXHIBIT by Plaintiff The Gillette Company LLC Exhibit 1 regarding supplement[28]

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's renewed, corrected ex parte motion for TRO [27] is granted. The plaintiff's previous, outstanding TRO motions [14] [25] are denied as moot. Enter temporary restraining order. Mailed notice

SEALED TEMPORARY Restraining Order Signed by the Honorable John J. Tharp, Jr on 6/2/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A" by Plaintiff The Gillette Company LLC

SUMMONS Issued (Court Participant) as to Defendant Guizhou Nine Fun Technology Co., Ltd. and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 37,000.00 posted by The Gillette Company LLC. (Document not scanned).

MOTION by Plaintiff The Gillette Company LLC to Extend the Temporary Restraining Order

MEMORANDUM by The Gillette Company LLC in support of motion for miscellaneous relief[35]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order [35] is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 6/16/2025. Mailed notice

NOTICE of Voluntary Dismissal by The Gillette Company LLC as to a certain Defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [39], defendant no. 37 is dismissed from this case. Mailed notice

SUMMONS Returned Executed by The Gillette Company LLC as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 6/25/2025, answer due 7/16/2025.

Declaration of Sydney Fenton

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MOTION by Plaintiff The Gillette Company LLC for preliminary injunction

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MEMORANDUM by The Gillette Company LLC in support of motion for preliminary injunction[42]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [42] is taken under advisement. Any objection or response is due before 6/30/25. The Court directs the plaintiff, by 6/27/25, 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 6/30/25. 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

CERTIFICATE of Service by Martin Francis Trainor on behalf of The Gillette Company LLC

Exhibit A

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 7/2/2025. Mailed notice

NOTICE of Voluntary Dismissal by The Gillette Company LLC as to a certain defendant

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment as to a certain defendant(AGREED)

MOTION by Plaintiff The Gillette Company LLC to strike notice of voluntary dismissal[47]

MINUTE entry before the Honorable John J. Tharp, Jr:The Court construes plaintiff's motion to strike the notice of voluntary dismissal [49] as a motion under FRCP 60(1) and grants the motion. The Court approves the motion for entry of a consent judgment [48]. Enter consent judgment. The civil case is terminated as to defendant no. 34. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 9/2/2025. Mailed notice