2025-cv-05556

COMPLAINT filed by NBA Properties, Inc.; Filing fee $ 405, receipt number AILNDC-23503536.

Exhibit 1

SEALED EXHIBIT by Plaintiff NBA Properties, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff NBA Properties, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by NBA Properties, Inc.

Notice of Claims Involving Trademarks by NBA Properties, Inc.

ATTORNEY Appearance for Plaintiff NBA Properties, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff NBA Properties, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff NBA Properties, Inc. by Allyson M. Martin

ATTORNEY Appearance for Plaintiff NBA Properties, Inc. by Kahlia Roe Halpern

MAILED trademark report to Patent Trademark Office, Alexandria VA.

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. 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: lincangyishuxisha_0, linwanyunshangmao, linyuanc, liuang, liuxiaofei5, liuziqia, LLMING, lmjks2sw, lubobo, luwei666, m_390301, magicalhouse1, mann_guyse, mawenhua, mbjuii, meiana, mi1_3906, mianda-13, mingshan-0, mjkgfh, mphmv78, na16320, nbghgj12, newsfys, newton_bown, ngzhouqinqin, nhspzdg, nu82066, oau7688, omjksw2, peieiue, pengyu1995, pinguan_5, pu3962, qgst_17, qiangene, qinwong, qixianliuxinshan-0, qsxg_43, quy_8093, r34755, reaete6, rvyh4138, s'tar stort, s67_47, saturn72, sbr302, sdmsdjh22, sdwd22, sdwsaa1, sdwsww2, Sexy lingerie store, shanghaiyouranwangl0, shengun749, shishi3331, shiuan, simplelifes, skjyh31, skm8jw7s, skmj7jy6s, skmjus887, sksm8ssw, sksmu88w, slkm77sw, slsmj8sw, sosk8j233, sportsclothing001, sportsclothing002, suiyu147, E xingle, FANwenfeng, Haiying Wangluo, jinanzhaoanriyongbaihuoxiao, LiuQiuTingShangMao, longfusheji, Mengwar, MIUMIUBAG, MS Pan, PLNQQB Shop, QIOPFWEJRG, RunningCreator LLC, shanghaiweiyoucaimaoyiyouxiangongsi, ShaShaWireless, shenzhenshixinhonghaowujinzhipin, Sun Dan Men's wear store, tangchangsheng, VIENGACHY CO.LTD, VILSOWAAP Co. ltd and WilbertNelson added to case caption.

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

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court grants the motion to seal [3], but upon review of the complaint, the Court sua sponte raises the propriety of joining nearly 150 defendants in a single action. By May 30, 2025, plaintiff must file a supplemental memorandum addressing the propriety of joinder. In the alternative, plaintiff has leave to file an amended complaint by May 30, 2025 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting the opinion issued in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025) (Alexakis, J.). Mailed notice.

AMENDED complaint by NBA Properties, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

(Exhibit 1)

SEALED EXHIBIT by Plaintiff NBA Properties, Inc. Amended Schedule A regarding amended complaint 14

MOTION by Plaintiff NBA Properties, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by NBA Properties, Inc. in support of motion for temporary restraining order 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

DECLARATION of Lindsay Conn regarding memorandum in support of motion 17

SEALED EXHIBIT by Plaintiff NBA Properties, Inc. Exhibit 1 - Parts 1-2 regarding declaration 19

Exhibit 1-1

(Exhibit 1-2)

DECLARATION of Ayala Deutsch regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

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

MEMORANDUM by NBA Properties, Inc. in support of motion for miscellaneous relief 22

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 23

SEALED DOCUMENT by Plaintiff NBA Properties, Inc. Schedule A Template

Registry Deposit Information Form by NBA Properties, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Amended Complaint by Plaintiff NBA Properties, Inc.

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

SURETY BOND in the amount of $ 10,000 posted by NBA Properties, Inc. Document not imaged.

NOTICE of Voluntary Dismissal by NBA Properties, Inc. as to a certain Defendant

MOTION by Plaintiff NBA Properties, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by NBA Properties, Inc. in support of motion for preliminary injunction[33]

Declaration of Allyson M. Martin

SUMMONS Returned Executed by NBA Properties, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/5/2025, answer due 6/26/2025.

Declaration of Kahlia R. Halpern

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by June 11, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff NBA Properties, Inc. regarding set motion and R&R deadlines/hearings, 36

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction [33] is granted, which the Court now considers unopposed because no defendant filed a notice of objection by the established deadline. For the reasons set forth in plaintiff's motion for a preliminary injunction, as well as the reasons provided by plaintiff in connection with the Court's earlier entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction, including that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established [37] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Lindsay C. Jenkins on 6/12/2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: By July 1, 2025, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

ATTORNEY Appearance for Plaintiff NBA Properties, Inc. by Justin Tyler Joseph

MOTION by Plaintiff NBA Properties, Inc. for entry of default as to all Remaining Defendants, MOTION by Plaintiff NBA Properties, Inc. for default judgment as to all Remaining Defendants

Exhibit A

MEMORANDUM by NBA Properties, Inc. in support of motion for entry of default, motion for default judgment, 42

Exhibit 1

Exhibit 2-1

(Exhibit 2-2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before July 8, 2025. If no objections are filed by that date, the court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by July 7, 2025. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiff NBA Properties, Inc. regarding text entry, [45]

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 42 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The Clerk is directed to return the surety bond posted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 7/9/2025. Mailed notice.