2025-cv-05344

COMPLAINT filed by K and K Promotions, Inc. ; Filing fee $ 405, receipt number AILNDC-23485424.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff K and K Promotions, Inc. Schedule A regarding complaint 1

MOTION by Plaintiff K and K Promotions, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by K and K Promotions, Inc.

Notice of Claims Involving Trademarks by K and K Promotions, Inc.

ATTORNEY Appearance for Plaintiff K and K Promotions, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff K and K Promotions, Inc. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff K and K Promotions, Inc. by Alexander Whang

CASE ASSIGNED to the Honorable April M. Perry. 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: [REDACTED] added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion to Seal [3] is granted. It appearing that the case filed is a "Schedule A" case, Plaintiff is directed to the Court's standing order on its website directing the filing of the Court's Schedule A Template within 14 days. Upon review of the complaint, the Court sua sponte raises the propriety under Federal Rule of Civil Procedure 20(a)(2) of joining 37 defendants to this action. See, e.g, Estee Lauder Cosmetics Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). Plaintiff should reference this Court's opinion in Zaful v. Schedule A Defs., 24-cv-11111, Doc. 12 (N.D. Ill. Jan. 10, 2025), where the Court expressed its views on joinder in such cases. By 6/2/2025, Plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of above cases. In the alternative, Plaintiff has leave to file an amended complaint by 6/2/2025 with a smaller subset of defendants along with a memorandum explaining why each defendant is properly joined to all of the others. Mailed notice. (jcc,)

AMENDED complaint by K and K Promotions, Inc. against [REDACTED]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff K and K Promotions, Inc. Schedule A regarding amended complaint[11]

SEALED EXHIBIT by Plaintiff K and K Promotions, Inc. Schedule of Defendants

MOTION by Plaintiff K and K Promotions, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by K and K Promotions, Inc. in support of motion for miscellaneous relief[14]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[15]

Exhibit 1

SEALED EXHIBIT by Plaintiff K and K Promotions, Inc. Exhibit 2 regarding declaration[16]

MOTION by Plaintiff K and K Promotions, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by K and K Promotions, Inc. in support of motion for miscellaneous relief[18]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[14], motion for miscellaneous relief[18] before Honorable April M. Perry on 5/28/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: Plaintiff's ex parte motion for entry of a temporary restraining order [14], including a temporary injunction, a temporary asset restraint, and expedited discovery, is granted. Plaintiff's Motion for Electronic Service of Process [18] is also granted. Plaintiff's written submissions establish that if Defendant was informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating Plaintiff's interests in identifying Defendant, stopping the infringement, and obtaining an accounting. The Court finds that (1) the submitted evidence establishes a likelihood of success on the merits (including evidence of active infringement and sales into Illinois); (2) the harm to Plaintiff is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with Plaintiff's ability to control its intellectual property; and (4) there is no countervailing harm to Defendant from an order directing it to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with an online marketplace defendant. Expedited discovery is warranted to identify Defendant and implement the asset freeze. If Defendant were to appear and object, the Court would revisit the asset freeze and personal jurisdiction. A $1,000 bond is sufficient to secure the injunctive relief. The Court strikes the motion hearing set for 5/28/2025. Enter order. Mailed notice. (jcc,)

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable April M. Perry on 5/23/2025. (jcc,)

SURETY BOND in the amount of $1,000 posted by K and K Promotions, Inc. (Document not scanned).

MOTION by Plaintiff K and K Promotions, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by K and K Promotions, Inc. in support of motion for miscellaneous relief[24]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[24] before Honorable April M. Perry on 6/5/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: Plaintiff's Motion to Extend the Temporary Restraining Order [24] is granted. The previously granted TRO [22] shall be extended until 6/20/2025. The Court strikes the hearing date of 6/5/2025. Enter order. Mailed notice. (jcc,)

SEALED Extension of Temporary Restraining Order. Signed by the Honorable April M. Perry on 6/3/2025. (jcc,)

SUMMONS Submitted (Court Participant) for defendant(s) HYXBNLKK by Plaintiff K and K Promotions, Inc.

SUMMONS Issued (Court Participant) as to HYXBNLKK that shall apply to Defendant.

NOTICE of Voluntary Dismissal by K and K Promotions, Inc. as to a certain Defendant

MINUTE entry before the Honorable April M. Perry: Notice of Voluntary Dismissal [31] is acknowledged. Pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure, this case is dismissed without prejudice. Any or all previously set deadlines/hearings to be struck. Civil case terminated. Mailed notice. (jcc,)