2025-cv-05792

COMPLAINT filed by SEKIGUCHI CO., LTD.; Filing fee $ 405, receipt number AILNDC-23529914.

Exhibit 1 - TM Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. - Schedule A to Complaint - regarding complaint 1

MOTION by Plaintiff SEKIGUCHI CO., LTD. to seal document exhibit 3

CASE ASSIGNED to the Honorable Elaine E. Bucklo. 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.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by SEKIGUCHI CO. LTD to Matthew A. Werber, 70 West Madison, Suite 5200, Chicago, IL 60602-4224 certified mail #9589 0710 5270 0579 7831 03

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by SEKIGUCHI CO., LTD.

ATTORNEY Appearance for Plaintiff SEKIGUCHI CO., LTD. by Matthew A. Werber

ATTORNEY Appearance for Plaintiff SEKIGUCHI CO., LTD. by Peter Krusiewicz

AMENDED complaint by SEKIGUCHI CO., LTD. against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

Exhibit 1 - TM Registrations

Exhibit 2 - CBP

Exhibit 3 - IP Rights

(Exhibit 4 - DHS)

SEALED EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. - Schedule A to Amended Complaint - regarding amended complaint, 8

MOTION by Plaintiff SEKIGUCHI CO., LTD. to seal document exhibit 9

MOTION by Plaintiff SEKIGUCHI CO., LTD. for temporary restraining order PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

MEMORANDUM by SEKIGUCHI CO., LTD. in support of motion for temporary restraining order 11 MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF

Declaration of Jay Harvey Paragoso

Declaration of Matthew Werber

(Unpublished)

SEALED EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. EXHIBIT 1 TO THE DECLARATION OF JAY HARVEY PARAGOSO (SEALED) regarding memorandum in support of motion, 12

Exhibit 1 - Part 1 of 2

(Exhibit 1- Part 2 of 2)

SEALED EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. EXHIBIT A TO THE DECLARATION OF MATTHEW A. WERBER (SEALED) regarding memorandum in support of motion, 12

(Exhibit A)

MOTION by Plaintiff SEKIGUCHI CO., LTD.FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE

Declaration of Matthew Werber

Exhibit A - to the Declaration of Matt Werber

Exhibit B - to the Declaration of Matt Werber

(Unpublished)

MEMORANDUM by SEKIGUCHI CO., LTD. -- MEMORANDUM ON JOINDER --

NOTICE of Motion by Matthew A. Werber for presentment of motion for temporary restraining order 11, motion for miscellaneous relief, 15, motion to seal document 10 before Honorable Elaine E. Bucklo on 6/4/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file exhibit under seal 4 10 ; Plaintiffs' Ex Parte motion for entry of temporary restraining order and other relief 11 ; Plaintiff's motion for expedited discovery and electronic service 15 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 6/18/2025, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 6/11/2025. Nixon Peabody LLP is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. 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 status hearing on 7/21/2025 at 9:45 a.m. (to track the case only, no appearance is required). By 7/14/2025 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 6/4/2025. Mailed notice.

REGISTRY DEPOSIT INFORMATION FORM - EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. (Received at the Intake Counter on 6/10/25.)

MOTION by Plaintiff SEKIGUCHI CO., LTD. for extension of time -- of TRO --

NOTICE of Motion by Matthew A. Werber for presentment of extension of time 21 before Honorable Elaine E. Bucklo on 6/18/2025 at 09:45 AM.

SURETY BOND in the amount of $10,000 posted by SEKIGUCHI CO., LTD. (Document not scanned)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion to extend temporary restraining order 21 is granted to 7/2/2025. Mailed notice.

SUMMONS Issued (Court Participant) as to luosifer and all other Defendants identified in the complaint

SUMMONS Returned Executed by SEKIGUCHI CO., LTD. as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto on 6/13/2025, answer due 7/4/2025.

(Executed Summons -- Served June 13, 2025)

MOTION by Plaintiff SEKIGUCHI CO., LTD. for preliminary injunction

(Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion for preliminary injunction 28 before Honorable Elaine E. Bucklo on 6/25/2025 at 09:45 AM.

MOTION by defendant Ylmarket to dismiss for failure to state a claim (Received via pro se online portal on 06/19/25.)

ORDER: Plaintiff is directed to respond to Defendant YLMarket 's motion to dismiss for failure to state a claim 30 on or before July 16, 2025, and must allege the type of legal person natural or otherwise it claims YLMarket to be. YLMarket will then have until July 30, 2025, to reply. If YLMarket is anything other than an individual or sole proprietorship, its reply must be through an attorney who has filed an appearance on Defendant's behalf. Signed by the Honorable Elaine E. Bucklo on 6/26/2025. Mailed notice.

NOTICE of Voluntary Dismissal by SEKIGUCHI CO., LTD. as to Certain Defendants

ATTORNEY Appearance for Defendants Sharp Cow, Dasabi Company by Timothy Tiewei Wang

MOTION by Defendants Dasabi Company, Sharp Cow for extension of time to file answer regarding complaint 1 Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 34 before Honorable Elaine E. Bucklo on 7/9/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Per voluntary dismissal no. 32, Defendant YLMarket 's motion to dismiss for failure to state a claim 30 is moot. Defendants Sharp Cow and Dasabi Company's unopposed motion to extend deadline to answer or otherwise respond to Plaintiff's Complaint 34 is granted to 7/25/2025. Mailed notice.

ATTORNEY Appearance for Defendants WOAMG, JGTUY, Keioly, JIASEN by Timothy Tiewei Wang

MOTION by Defendants JGTUY, JIASEN, Keioly, WOAMG for extension of time to file answer regarding complaint 1 Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 38 before Honorable Elaine E. Bucklo on 7/10/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants WOAMG, JGTUY, Keioly and JIASEN's unopposed motion to extend deadline to answer or otherwise plead to Plaintiff's amended complaint 38 is granted to 7/25/2025. Mailed notice.

MOTION by Plaintiff SEKIGUCHI CO., LTD. to substitute party - Substitute Joybuy Defendants -

(Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion to substitute party 41 before Honorable Elaine E. Bucklo on 7/11/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's unopposed mOTION to substitute Joybuy Defendants 41 is granted. Mailed notice.

ORDER signed by the Honorable Elaine E. Bucklo on 7/15/2025. Mailed notice.

SUMMONS Returned Executed by SEKIGUCHI CO., LTD. as to Defendants 50 - 57 on 7/15/2025, answer due 8/5/2025.

(Return of Service Executed)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff failed to file a status report required by minute entry no. 18. Plaintiff's motion for entry of preliminary injunction 28 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: (i) Amended Schedule A to the Amended Complaint [Dkt. 9]; (ii) Exhibit 1 to the Declaration of Jay Harvey Paragoso [Dkt. 13]; (iii) Exhibit A to the Declaration of Matthew A. Werber [Dkt. 14]; and (iv) the TRO Order [Dkt. 19]. Pending Defendants' responsive pleading due 8/5/2025, Status hearing is reset for 8/21/2025 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 8/14/2025. The court will enter a scheduling order in response to the status report. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 7/21/2025. Mailed notice.

NOTICE of Voluntary Dismissal by SEKIGUCHI CO., LTD. as to certain defendants

MOTION by Plaintiff SEKIGUCHI CO., LTD. for default judgment as to Certain Defendants

MEMORANDUM by SEKIGUCHI CO., LTD. in support of motion for default judgment[49]

Ex. A Defaulting Defendants

Werber Declaration

Unpublished NDIL-1-21-cv-02563

Other Unpublished

NOTICE of Motion by Matthew A. Werber for presentment of motion for default judgment[49] before Honorable Elaine E. Bucklo on 7/24/2025 at 09:45 AM.

EXHIBIT by Plaintiff SEKIGUCHI CO., LTD. - Corrected Exhibit A - Defaulting Defendants - regarding memorandum in support of motion 50

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's Motion for Entry of Default and Default Judgment 49 is reset for 8/21/2025 at 10:00 a.m. Mailed notice.

MOTION by Defendants Dasabi Company, JGTUY, JIASEN, Keioly, Sharp Cow, WOAMG for extension of time to file answer regarding complaint 1 Unopposed

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer 54 before Honorable Elaine E. Bucklo on 7/31/2025 at 09:45 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants WOAMG, JGTUY, Keioly, JIASEN, Sharp Cow and Dasabi Company's (second) unopposed motion to extend deadline to answer or otherwise respond to Plaintiff's amended complaint 54 is granted to 8/15/2025. Pending Defendants' responsive pleading, status hearing is reset for 9/2/2025 at 9:45 a.m. (to track the case only, no appearance is required). The parties shall file a joint written status report by 8/26/2025. The Court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by SEKIGUCHI CO., LTD. as to Certain Defendants

STATUS Report by SEKIGUCHI CO., LTD.

MOTION by Plaintiff SEKIGUCHI CO., LTD. for default judgment as to - Remaining Defaulting Defendants -, MOTION by Plaintiff SEKIGUCHI CO., LTD. for entry of default

MEMORANDUM by SEKIGUCHI CO., LTD. in support of motion for default judgment, motion for entry of default 59 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S SECOND MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMENT

Exhibit A - Remaining Defaulting Defendants

Declaration of Matt Werber

Unpublished

(Other Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion for default judgment, motion for entry of default 59 before Honorable Elaine E. Bucklo on 8/21/2025 at 10:00 AM.

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of default and default judgment [49] and second motion for entry of default and default judgment [59] is granted. Enter Default Judgment Order and Second Default Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to Plaintiff or its counsel Nixon Peabody LLP. All pending dates and motions are terminated as moot. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/21/2025. Mailed notice.

SECOND DEFAULT JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 8/21/2025. Mailed notice.

EMAILED Trademark report with certified copy of minute order dated 08/22/25 to Patent Trademark Office, Alexandria VA

RETURN of U.S. Post Office Receipt, article no. number 9589 0710 5270 0579 7831 03 (Received by mail in the Clerk's Office on 09/04/25.)