2025-cv-05716

COMPLAINT filed by Crye Precision LLC; Filing fee $ 405, receipt number AILNDC-23520189.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Crye Precision LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Crye Precision LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Crye Precision LLC

Notice of Claims Involving Trademarks by Crye Precision LLC

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Madeline Halgren

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED copyright report to Registrar, Washington DC.

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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: DYL5662, haosidianzishangwuyouxiangongsi, Outuo US, SBD TACTICAL, sunlibo, cvlife-sport, dairoux_25, DaJiang, East Horizon Retail, easymart2016-8, edc player, ezshoot-life, Family Life's, Fivestarsseller2012, greenvivid, hangfushangmao, hello-kk, iceblinkieshop, JourneyFlight, keepmoving77, khyany2013, Laptop-Cyber, lechantdelamer, lfxdigital, luciernaga, Lucky Sports Store, luckyxi_73, mejego, midten-direct, new88, Outdoorsports, qqqi44, ranp_3314, sexywh-13, sportsgoodlife, StrengthTrainingstore, sunshine-565, topdealere, Um.1995, usacyber, USA-CyberLink, whole shore, x19103li, xinxinlin88, yaoya_63, znewnew, zomeiplus18, Abastado, aoanydony, Apuakthei, AUSCAMOTEK, Benafini, Boovnll, BrowQuartz, ChYoung Choicest, Ckgkwkod, dihao, Doailam, Fearlessin, Garnet, GENGING, guardung, Gueiykk, IPEWLEX Cozy Corner, jianteyi, jiuqiyao, justhard, LeiKong, LIANCE STORE, Lolmot, Njide, Outdoor Xplorer, OXM MALL, Paraugas, PENGXIANG Co. Ltd, qiyuannongmu, Quickwittc, Senda NestWorks Co.,Ltd, Shedom, Taiqixu, TMOYZQ, TRGPSG, UltraKey, Weisidun, xiouyu, XiY Enterprise and YABCSAZ Apparel Fashion added to case caption.

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 more than 100 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 Crye Precision LLC against The Partnerships and Unincorporated Associations Identified on Schedule A

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Crye Precision LLC Amended Schedule A regarding amended complaint[14]

MOTION by Plaintiff Crye Precision LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Crye Precision LLC in support of motion for temporary restraining order[16]

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

DECLARATION of Jonathan E. Antone regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Crye Precision LLC Exhibit 3 Parts 1-2 regarding declaration[19]

MOTION by Plaintiff Crye Precision LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Crye Precision LLC in support of motion for miscellaneous relief[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

SEALED DOCUMENT by Plaintiff Crye Precision LLC Schedule A Template

Registry Deposit Information Form by Crye Precision LLC

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

SURETY BOND in the amount of $ 10,000 posted by Crye Precision LLC. (Document not scanned).

MOTION by Plaintiff Crye Precision LLC for preliminary injunction

Exhibit A

MEMORANDUM by Crye Precision LLC in support of motion for preliminary injunction[31]

Declaration of Kahlia R. Halpern

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

Declaration Madeline B. Halgren

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 Crye Precision LLC regarding set motion and R&R deadlines/hearings, 34

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 31 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 35 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.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Andrew Daniel Burnham

MOTION to Dismiss Plaintiff's Complaint under Rules 12(b)(2) and 12(b)(6) of the Federal Rules of Civil Procedure by Defendant Apuakthei, online store owned by Yang Yuanyuan, who locates in Ningxia, China. (Received via pro se online portal on 6/24/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's response to Defendant Apuakthei's motion to dismiss is due by July 3, 2025. Mailed notice.

MOTION by Plaintiff Crye Precision LLC to strike MOTION by Defendant Apuakthei to dismiss [42]

Exhibit 1

Exhibit A

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

ATTORNEY Appearance for Defendant TRGPSG by Timothy Tiewei Wang

MOTION by Defendant TRGPSG for extension of time to file answer regarding complaint[1] Unopposed

MINUTE entry before the Honorable Lindsay C. Jenkins: The unopposed motion for an extension of time by Defendant TRGPSG [47] is granted. Defendant TRGPSG's responsive pleading is now due by July 17, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to strike [44] is granted. A motion was filed pro se by Mr. Yang Yuanyuan who purports to be owner of Apuakthei, but there is no explanation of the grounds for Yang Yuanyuan to represent a business entity such as Apuakthei, nor is there any indication that Yuanyuan is licensed to practice law in the United States. The motion to dismiss [42] is denied without prejudice to refiling by an attorney authorized to represent Defendant Apuakthei. Mailed notice.

MOTION by Plaintiff Crye Precision LLC for entry of default, MOTION by Plaintiff Crye Precision LLC for default judgment as to certain Defendants

(Exhibit A)

MEMORANDUM by Crye Precision LLC in support of motion for entry of default, motion for default judgment 50

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 51

(Exhibit 1)

STATUS Report Pursuant to 38 by Crye Precision LLC

(Exhibit A)

ATTORNEY Appearance for Defendants Boovnll, IPEWLEX Cozy Corner, Lolmot, YABCSAZ Apparel Fashion by Adam Edward Urbanczyk

MOTION by Defendants Boovnll, IPEWLEX Cozy Corner, Lolmot, YABCSAZ Apparel Fashion for extension of time

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendant TRGPSG. 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 9, 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 Crye Precision LLC regarding order on motion for entry of default, order on motion for default judgment, text entry, [56]

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants Boovnll, IPEWLEX Cozy Corner, Lolmot, YABCSAZ Apparel Fashion's motion for an extension of time [55] is granted. These Defendants' responsive pleading is now due by July 23, 2025. Mailed notice.

MOTION by Plaintiff Crye Precision LLC to approve consent judgment as to Defendant No. 50 (Agreed)

Exhibit A

MINUTE entry before the Honorable Lindsay C. Jenkins: By July 11, 2025, Plaintiff shall submit a revised default judgment order to the Court's PO Box and file any appropriate stipulations of dismissal so that the court can determine which, if any, Defendants remain active in the case. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for a consent judgment [59] is granted. Separate order to issue. Mailed notice.

ENTERED DEFAULT JUDGMENT as to certain defendants Signed by the Honorable Lindsay C. Jenkins on 7/10/2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Boovnll (Def. No. 53), IPEWLEX Cozy Corner (Def. No. 64), Lolmot (Def. No. 70), TRGPSG (Def. No. 82), and YABCSAZ Apparel Fashion. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [50] 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. Enter Final Judgment Order. Mailed notice.

ENTERED DEFAULT JUDGMENT as to certain defendants Signed by the Honorable Lindsay C. Jenkins on 7/10/2025. Mailed notice.

ENTERED CONSENT JUDGMENT as to certain defendant Signed by the Honorable Lindsay C. Jenkins on 7/11/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

FULL SATISFACTION of Judgment regarding entered judgment[65] in the amount of $50,000 as to certain defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The only remaining Defendant TRGPSG's responsive pleading was due by July 17, 2025, but nothing was filed. Therefore the court enters default as to this Defendant under FRCP 55(a). Plaintiff's motion for default judgment under FRCP 55(b) is to be filed no later than July 23, 2025. Mailed notice.

MOTION by Plaintiff Crye Precision LLC for default judgment as to Defendant No. 82

Exhibit A

MEMORANDUM by Crye Precision LLC in support of motion for default judgment[70]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[71]

Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of default judgment against Defendant TRGPSG, who has failed either to plead or to otherwise appear to defend against this action. Any objections to the motion for entry of default judgment must be filed on or before July 30, 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 28, 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 Crye Precision LLC regarding text entry, [73]

Exhibit A

FULL SATISFACTION of Judgment regarding entered judgment[63] in the amount of $50,000 as to certain defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant TRGPSG has not responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [70] 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.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Lindsay C. Jenkins on 7/31/2025. Mailed notice.

FULL SATISFACTION of Judgment regarding order[77] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding entered judgment[63] in the amount of $20,000 as to certain defendant