2025-cv-05555

COMPLAINT filed by Harley-Davidson Motor Company, Inc.; Filing fee $ 405, receipt number AILNDC-23503538.

Exhibit 1

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for leave to file under seal

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Harley-Davidson Motor Company, Inc.

CIVIL Cover Sheet

Notice of Claims Involving Trademarks by Harley-Davidson Motor Company, Inc.

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Harley-Davidson Motor Company, Inc. by Rachel Meira Ackerman

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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: A331W6E0D48GQU, A3AKROFR5ZQUJW, chenhaihuibuness, egrhrjj, GuangZhouTengHuiShangMao, GuangZhouZhaoLiMaoYiYouXianGongSi, Healthy, jinxiangxiannianyu, jinxiangxianqiangqi, Lin Decor, nanxingpeijiancheng, nanyangshihaochenwangluokejiyouxiangongsi, wuhanchenhaomaoyiyouxiangongsi, yinbao store, yushibingjdiasdiahsdiahfassnfkaf, zhiweism, 2016number4store, f24hangzhoubiz, Aluminum round ornament, bantianyicuo, BINLI ART, Burn my world, Canva Art, Canvas Canvasland, CGCD, Chi Hong Boutique, DPDB, Fashion boy T, Fashionable Clothing Co Ltd, Fen Popular, FSCLEEOD, FurCanvas Art, Galvin Decoration, Hemitongm, Iron Intentionalism local, IronCanvasArt, Jin Cheng Wu, KANG B, LOVESSYYCCJJ, Lthg two, Lucky Sweetie Fine, LYchangmingTrade, Minimal Style, Mr Xu the iron worker, MY BudgetMart, My Fonori, MY SmartShopper, Nemophiisii SHOP, NeoNexus, New start point, New start point NO two, NKNA, NoDiDi, onbuy, Pignoesa, Please stay when you come, qiaopideyoumo, SHIBUBAIHUO, Showmemars, SHUNBANGPOD local, The Canvas Artistry, TigTal, Tin painting shop O, UnitTBase, Vintage Metal Works, Vintage Painting Two, xiaoxitiepibao, XUEKAIWEN, YQAWanxin, ZapDeck, Zentora, Zhi Blanket, HK-shirts and jibanzhuo added to case caption.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for temporary restraining order 13

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

DECLARATION of Adraea M. Brown regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Harley-Davidson Motor Company, Inc. Exhibit 2 - Parts 1-2 regarding declaration 16

Exhibit 2-1

(Exhibit 2-2)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for miscellaneous relief 18

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

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [18] are granted. Plaintiff's motion for entry of an ex parte temporary restraining order [13] is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 6/13/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 6/10/2025. Plaintiff is advised that the Court may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 5/30/2025.

Registry Deposit Information Form by Harley-Davidson Motor Company, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Harley-Davidson Motor Company, Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and all other Defendants identified in the Complaint

Surety BOND in the amount of $ 10,000 posted by Harley-Davidson Motor Company, Inc. (Document not Imaged) (Received via mail at the Clerk's Office on 6/5/2025)

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of extension of time[26]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[27]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of of the temporary restraining order [26] is granted; the ex parte TRO entered by the Court on 5/30/2025 is extended through 6/27/2025. The telephonic preliminary injunction hearing set for 6/13/2025 is vacated and reset to 6/27/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction must be filed by 6/24/2025. Plaintiff is reminded that the Court may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for preliminary injunction[31]

Declaration of Marcella D. Slay

SUMMONS Returned Executed by Harley-Davidson Motor Company, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/11/2025, answer due 7/2/2025.

Declaration of Rachel M. Ackerman

Exhibit A

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or answer or response to the motion for preliminary injunction motion. The telephonic preliminary injunction set for 6/27/2025 is vacated. Plaintiff's motion for entry of a preliminary injunction 31 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 8/29/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 8/22/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 6/25/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for entry of default, MOTION by Plaintiff Harley-Davidson Motor Company, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Harley-Davidson Motor Company, Inc. in support of motion for entry of default, motion for default judgment, [38]

Exhibit 1

Exhibit 2-1

Exhibit 2-2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[39]

Exhibit 1

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Harley-Davidson Motor Company, Inc. as to certain defendants

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for entry of default [38] is granted. Final Default Judgment Order to follow. Any hearing dates set before this Court are vacated. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Matthew F. Kennelly on 8/4/2025. Mailed notice.

MAILED trademark report with order dated 8/4/2025 to Patent Trademark Office, Alexandria VA

NOTICE of withdrawal of SURETY BOND [29] in the amount of $ 10,000 posted by Harley-Davidson Motor Company, Inc. by Counsel/Designated person.

FULL SATISFACTION of Judgment regarding Default Judgment, order[45] in the amount of $100,000 as to certain defendant