2025-cv-05892

COMPLAINT filed by Bounce Curl, LLC; Filing fee $ 405, receipt number AILNDC-23537791.

Exhibit 2

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 1 regarding complaint[1]

MOTION by Plaintiff Bounce Curl, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bounce Curl, LLC

Notice of Claims Involving Patents by Bounce Curl, LLC

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Andrew Daniel Burnham

ATTORNEY Appearance for Plaintiff Bounce Curl, LLC by Jennifer Van Nacht

EMAILED Patent report to Patent Trademark Office, Alexandria VA

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 1).

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: A2OARGPTUGLU4U, AS6VB1OV4MY56, dedaohair, FENGLAIWEI, fuyangenqitongxunqicaixiaoshouyouxiangongsi, fuzhoucaimashangmaoyouxiangongsi, GuangZhouQinHengShangMao, guangzhoushuyongshangmaoyouxiangongsi, GUlZ, HaiChiKang, hzly, Jianeil-US, JOBOO STORE, licongfushi, LiLuMing2024, Lontin zone, LuLeixiaodian, Nuanyisheng, Tongling Yikecai Trading Co., Ltd, WEIWEIHAOWU, Williey, Xiaohongfushi, XINGTUBAI, fairyenjoysale, metersdter_limvits, bialidaojia, Dog Flying, DYM Accessories, jucjvhnn, linbaoshengSHOP, Mlthree, openstore, VerJie Mall, weathes, baodan 666, CaiXuan LTD, chilifuzhuangyouxiangongsi, deeyoung, FFIIL, Hochexin, ruienshangmao, shuyan, yuanyibomaoyi and zhongpushangmao added to case caption.

MAILED Original Forty-Four Thousand- and 00/100-Dollars surety bond posted by Bounce Curl, LLC to Amy Crout Ziegler Greer, Burns & Crain Ltd. 200 W Madison St., Ste 2100 Chicago, IL 60606 certified mail # 9589 0710 5270 0579 7830 97

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for leave to file under seal [4] is granted. By 6/5/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

RESPONSE by Plaintiff Bounce Curl, LLC to order on motion for leave to file, terminate motions, [13]

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

MEMORANDUM by Bounce Curl, LLC in support of motion for temporary restraining order[15]

Exhibit 2

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 1 regarding memorandum in support of motion[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

DECLARATION of Merian Odesho regarding memorandum in support of motion[16]

Exhibit 1

SEALED EXHIBIT by Plaintiff Bounce Curl, LLC Exhibit 2 regarding declaration[19]

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

MEMORANDUM by Bounce Curl, LLC in support of motion for miscellaneous relief 21

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

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motions for a temporary restraining order [15] and electronic service [21] are taken under advisement. By 6/24/25, the plaintiff is required to supplement its motion with (1) a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding, and (2) a supplemental brief explaining why joinder is proper under the America Invents Act, 35 U.S.C. § 299, particularly given that not all defendants seem to sell the same product. See, e.g., Oakley, Inc. v. Schedule A, No. 21-cv-00536, 2021 WL 308882, at *1-2 (N.D. Ill. Jan. 30, 2021) (propriety of joinder tied to sale of same accused product, and allegation "that the defendants all sold infringing products" insufficient). Mailed notice

SUPPLEMENT to motion for temporary restraining order[15]

MEMORANDUM by Bounce Curl, LLC Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum[26]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for a temporary restraining order [15] is granted. Enter temporary restraining order. The plaintiff's motion for electronic service of process [21] is also granted. Finally, on review of the plaintiff's memorandum [26] and supporting evidence, the Court finds that the plaintiff has set forth sufficient allegations and evidence to establish that joinder is proper under the America Invents Act, 35 U.S.C. § 299. Specifically, the plaintiff has preliminarily shown that the defendants' alleged infringement is part of the same "series of transactions or occurrences" and that they are selling "the same accused product or process" as required by § 299(a)(1). Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 6/10/2025. Mailed notice

Registry Deposit Information Form by Bounce Curl, LLC

SURETY BOND in the amount of $ 44,000.00 posted by Bounce Curl, LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Bounce Curl, LLC

SUMMONS Issued (Court Participant) as to Defendant A2OARGPTUGLU4U and all other Defendants identified in the Complaint

MOTION by Plaintiff Bounce Curl, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Bounce Curl, LLC in support of motion for preliminary injunction[34]

Declaration of Andrew D. Burnham

SUMMONS Returned Executed by Bounce Curl, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/18/2025, answer due 7/9/2025.

Declaration of Jennifer V. Nacht

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [34] is taken under advisement. Any objection or response is due by 6/23/25. The Court directs the plaintiff, by 6/21/25, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed by 6/23/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service by Plaintiff Bounce Curl, LLC regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [37]

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [34] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 6/27/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 6/25/2025. Mailed notice

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) [41], defendants 3, 23, 38 are dismissed from this case. Mailed notice

ATTORNEY Appearance for Defendant FFIIL by Timothy Tiewei Wang

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

MINUTE entry before the Honorable John J. Tharp, Jr:The motion for extension of time 44 is granted. The answer or otherwise responsive pleading is due 7/30/2025. Mailed notice

NOTICE of Voluntary Dismissal by Bounce Curl, LLC as to Certain Defendants

MOTION by Plaintiff Bounce Curl, LLC for entry of default, MOTION by Plaintiff Bounce Curl, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Bounce Curl, LLC in support of motion for entry of default, motion for default judgment[47]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[48]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable John J. Tharp, Jr:By 8/1/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

NOTICE of Correction.

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [47] is taken under advisement. Any objections or responses are due by 8/8/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 7/31/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service by Plaintiff Bounce Curl, LLC regarding order on motion for entry of default, order on motion for default judgment, set motion and R&R deadlines/hearings, [52]

Exhibit A

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [47] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 8/14/2025. Mailed notice

EMAILED Patent report with a certified copy of the order dated 08/14/25 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order[55] in the amount of THE JUDGMENT AMOUNT as to certain defendant

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment [57], the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants No. 4. Mailed notice

RETURN of U.S. Post Office Receipt number 9589 0710 5270 0579 7830 97