2025-cv-05557

COMPLAINT filed by Quanzhou Yongchun Beilang E-Commerce Co., Ltd.; Filing fee $ 405, receipt number AILNDC-23503532.

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. Trademark Registration regarding complaint 1

SEALED EXHIBIT by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. Genuine Listing regarding complaint 1

ATTORNEY Appearance for Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. by Zhiwei Hua

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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: ganhongxiukejiyoux, Gina Pierre, IZPXTQ Rosalind, Jinan Dayou Culture Media Co., Ltd, KLEKNI, Milianiapor, quantumshop, Spidey's Backpack Boutique, wuhanshifangzhigeshangmao and ZKKD--shop added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Quanzhou Yongchun Beilang E-Commerce Co., Ltd. against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit trademark registration

Exhibit Schedule A

(Exhibit Genuine Listing)

MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. for temporary restraining order and expedited discovery

SEALED DOCUMENT by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. Declaration of Yuanfang Pan

SEALED EXHIBIT by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. regarding MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. for temporary restraining order and expedited discovery 10, sealed document 11

Exhibit trademark registration

(Exhibit Schedule B)

DECLARATION of ZHIWEI HUA regarding motion for temporary restraining order 10 and expedited discovery

Exhibit 1 to Declaration

Exhibit 2 to Declaration

Exhibit 3 to Declaration

Exhibit 4 to Declaration

(Exhibit 5 to Declaration)

MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. Electronic Service of Process Pursuant to FRCP 4(f)(3)

Declaration of Zhiwei Hua in Support of Motion for Electronic Service

Exhibit 1 of Hua's Declaration

(Exhibit 2 of Hua's Declaration)

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary asset restraint, and expedited discovery 10 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 14 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 5/28/2025. Mailed notice.

MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. for extension of time of TRO

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the temporary restraining order [19] is granted. The TRO is extended for a period of fourteen (14) days until 6/25/2025. Mailed notice.

MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. for preliminary injunction

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 6/24/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 23 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Plaintiff's Pleading(s) [DOCKET NO.1] and Exhibits 1 - 3 thereto [DOCKET NO.2], [DOCKET NO.3], [DOCKET NO.4], Schedule A to the Pleading(s) [DOCKET NO(s).3], Exhibit 2 to the Declaration of Owner [DOCKET NO.12], and the TRO [DOCKET NO.17]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 7/30/2025 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 6/24/2025. Mailed notice.

MOTION by Plaintiff Quanzhou Yongchun Beilang E-Commerce Co., Ltd. for default judgment as to Defaulting Defendants identified on Schedule A

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 7/30/2025. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for default judgment [29] is granted. Enter order. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 7/30/2025. Mailed notice.