2025-cv-05506

COMPLAINT filed by Collegiate Licensing Company, LLC; Filing fee $ 405, receipt number AILNDC-23498869.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Collegiate Licensing Company, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collegiate Licensing Company, LLC

Notice of Claims Involving Trademarks by Collegiate Licensing Company, LLC

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Allyson M. Martin

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Rachel S Miller

MAILED trademark report to Patent Trademark Office, Alexandria VA.

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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: Yiwu Baoju Jewelry Co., Ltd., Yiwu Huayi Hat Industry Co., Ltd., linfenshijinhongshangmaoyouxianzerengongsi, Mudanjiang Caiwan Trading Co., Ltd., Phuongngoc, podianw, quanzhouguanglvshiyeyouxiangongsi, rangdanus, RichnRicherFashion, ROSEDY, Runlongguang, RUSYIEN, sex2323, shousenlyl, SMART FL, Tangshan Feijie Technology Co., Ltd., TB_Clothes, US Pellet Store(Fast Delivery 7-14Days), fuyi1990, lulu_baby, qzssdh1, maolai34, maolai37, minzha47, nguy6677, niluo2255, osmond_grandy, oxn138, patton_batcheller, pphq5869, putnam_dail, qianniao-6, qizhou39, quhoan_54, qunlin51, rc74744, rmfi8086, rongyang7, rongyou530, s-8612, songli-668, tangostore_8886, th757170, therezassa, tiantian856, ticiano66, tongmei1, VCraft, veronijka_m0sc, manmanT, Mattelstyle, ME Tshirt, Modern Crew, Modern Gent, MODERN GENTS, Monday MUSE, Motajisen, Natural Fashion House, Nature Star, NewDiy Zone, NEWDV Specialty, NiceNest, NIUQIANG, NovaNoook, NYI Maverick Apparel, OPEN GIFT, Panda Textile Factory, Positive Man, Premium local, PRHOO, PrimeCurated, Printmaking art, Professi Design, PTCY Fashion mens wear, QEEIE CUP, Qiaojiangnan Factory, QINGLONG RRR, QLMY Accessory, QLMYTXU, Qster vvp, QualitySelect, Queen Couture, RAYs shop, Red Rise mens, Retro literature and art, rkiuh, ROBESUNG, Rose Fabric Factory, Rose Pink Waves, RZ Clothes, saettaa, SELECT STYLES, Senpanion, sexiang, Shangsheng trendy clothing CCC, shiping led, SHUNBANGtshirt, Singularity Fashion Studio, SluckyshopS, Small Cradle, SnuggleSoft, SOUNDFAM, special blanket, specific blanket, SQH fashion, SSGOODSHOP, StandingTall, Stider, StyleOdyssey, Stylish Zone, SumllyN, Sunny handsome big boy, Sunset clothes shop, Super Coool, Swift Spark, Teechic DIY, HOKIPRD, JHDQ Shop, liusha, Sassalill t-shirt, SWANGG, WEM TIAN SHENG, WKSA and wuhantingyongenshangwu added to case caption.

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

MOTION by Plaintiff Collegiate Licensing Company, LLC for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for temporary restraining order[13]

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

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Lindsay Conn regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Exhibit 1 - Parts 1-2 regarding declaration[16]

DECLARATION of Sterling Hawkins regarding memorandum in support of motion[14]

Exhibit 1

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

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for miscellaneous relief[19], motion for temporary restraining order[13] before Honorable Jorge L. Alonso on 5/29/2025 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions [3] [13] [19] 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 $124,000--$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 5/29/25 is stricken. Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 5/28/2025. Notice mailed by Judge's staff

Registry Deposit Information Form by Collegiate Licensing Company, LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Collegiate Licensing Company, LLC

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

SURETY BOND in the amount of $ 124,000 posted by Collegiate Licensing Company, LLC. (Document not scanned)

MOTION by Plaintiff Collegiate Licensing Company, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Collegiate Licensing Company, LLC in support of extension of time[29]

DECLARATION of Allyson M. Martin regarding memorandum in support of motion[30]

NOTICE of Motion by Allyson M. Martin for presentment of extension of time[29] before Honorable Jorge L. Alonso on 6/11/2025 at 09:30 AM.

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Lucas Allen Peterson

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Ex Parte Motion to extend the temporary restraining order [29] is granted. The temporary restraining order is extended for 14 days until 6/25/25. Motion hearing date of 6/11/25 is stricken. Notice mailed by Judge's staff

MOTION by Plaintiff Collegiate Licensing Company, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for preliminary injunction[35]

Declaration of Allyson M. Martin

NOTICE of Motion by Allyson M. Martin for presentment of motion for preliminary injunction[35] before Honorable Jorge L. Alonso on 6/24/2025 at 09:30 AM.

Exhibit A

SUMMONS Returned Executed by Collegiate Licensing Company, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/16/2025, answer due 7/7/2025.

Declaration of Rachel S. Miller

Exhibit A

MINUTE entry before the Honorable Jorge L. Alonso: 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 Collegiate Licensing Company, LLC by Justin Tyler Joseph

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction [35] 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 8/14/25 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 6/24/2025. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 8/28/25 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

MOTION by Plaintiff Collegiate Licensing Company, LLC to approve consent judgment as to Certain Defendants

Exhibit A

MOTION by Plaintiff Collegiate Licensing Company, LLC for entry of default as to all Remaining Defendants, MOTION by Plaintiff Collegiate Licensing Company, LLC for default judgment as to all Remaining Defendants

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for entry of default, motion for default judgment, [45]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[46]

Exhibit 1

NOTICE of Motion by Allyson M. Martin for presentment of motion for entry of default, motion for default judgment, [45], motion to approve consent judgment[44] before Honorable Jorge L. Alonso on 8/28/2025 at 09:30 AM.

Exhibit A

ATTORNEY Appearance for Defendants NiceNest, NovaNoook by Christopher James Fahy

ATTORNEY Appearance for Defendants NiceNest, NovaNoook by Xuanjie Wang

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Thomas Joseph Juettner

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of consent judgment as to certain Defendants 44 is granted. Enter Consent Judgment. Plaintiff's Motion for entry of default and default judgment as to all remaining Defendants 45 is granted, over the objection of Defendants NiceNest and NovaNoook. Enter Final default judgment order. Civil case terminated. Notice mailed by Judge's staff

CONSENT Judgment. Signed by the Honorable Jorge L. Alonso on 8/28/2025. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 8/28/2025. Notice mailed by Judge's staff

MAILED Trademark report with certified copy of minute order dated 8/28/2025 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order 54 in the amount of $150,000 as to certain defendants