2025-cv-05893

COMPLAINT filed by Elizabeth's Studio LLC; Filing fee $ 405, receipt number AILNDC-23537815.

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Elizabeth's Studio LLC Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Yanling Jiang

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Yi Bu

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Elizabeth's Studio LLC by Christopher Romero

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Elizabeth's Studio LLC

MAILED copyright report to Registrar, Washington DC

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 3).

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: jufengruanjianjishu, kenzi77, Hadvgc, putianshilunpumaoyiyouxiangongsi, caoaihua, BEUU(Deliver in 7-14 Days), HOXZODT, Cheifay, Prime Day Deals Today 2024(7-13 days delivery), WHHFOOH(7-12 Business Days Delievered), YoyourIe, Muscularfit US, Erdkk, jingjingjjj, XingXuStore-US, YUNUOHAOKEJI, DYGUYTH, DINGLIA, Early Prime Day Deals 2024, Goddess Accent and XIAXOGOOL 7-15 days delivery added to case caption.

SEALED DOCUMENT by Plaintiff Elizabeth's Studio LLC Amended Schedule A to the Complaint 1 and Schedule A 2

MOTION by Plaintiff Elizabeth's Studio LLC for leave to file under seal

MOTION by Plaintiff Elizabeth's Studio LLC for leave to file excess pages

MEMORANDUM in support of 16 Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-2,of Keith A. Vogt's declaration

Declaration of Elizabeth Shnayder

(Exhibit 1, of Elizabeth Shnayder's declaration)

SEALED EXHIBIT by Plaintiff Elizabeth's Studio LLC Sealed Exhibit 2, Declaration of Elizabeth Shnayder regarding memorandum in support of motion, 17

(Exhibit 2-1)

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal 14, motion for leave to file excess pages 15, and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and for electronic service of process 16 are granted as to Amended Schedule A. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 8/1/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 6/17/2025. Mailed notice

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

SURETY BOND in the amount of $ 10,000.00 posted by Elizabeth's Studio LLC

MOTION by Plaintiff Elizabeth's Studio LLC for extension of time of the Temporary Restraining Order

MOTION by Plaintiff Elizabeth's Studio LLC for preliminary injunction

MEMORANDUM by Elizabeth's Studio LLC in support of motion for preliminary injunction 24

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

SUMMONS Returned Executed by Elizabeth's Studio LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/27/2025, answer due 7/18/2025.

(Declaration of Service, Keith A. Vogt)

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for extension of the TRO 23 is granted. The TRO entered on 6/17/25 is extended to 7/15/25. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 24. 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 or before July 9, 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 order entering the TRO, the TRO is extended to and including the date upon which 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 Fed.R.Civ.P. 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 Elizabeth's Studio LLC regarding terminate deadlines and hearings, 29

ATTORNEY Appearance for Defendants SenRuya, Mameqrsaterbr by Christopher Paul Keleher

MOTION by Defendants Mameqrsaterbr, SenRuya for extension of time to file answer regarding complaint 1 (UNOPPOSED)

MINUTE entry before the Honorable Jeffrey I Cummings: Defendants SenRuya and Mameqrsaterbr's unopposed motion for extension of time to answer or otherwise plead 32 is granted. If this matter is not resolved as to those defendants, they shall answer or otherwise plead by 8/6/25. Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MOTION by Plaintiff Elizabeth's Studio LLC for default judgment as to The Defendants Identified In First Amended Schedule A

MEMORANDUM by Elizabeth's Studio LLC in support of motion for default judgment 36

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 1 jufengruanjianjishu and defendant no. 29 ELEQIN

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 24 is granted as to the remaining defendants. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds 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 that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Plaintiff's counsel shall submit an updated proposed preliminary injunction order reflecting only the remaining defendants to the Court's proposed order inbox by 8/27/25. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 36 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, an order of 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 8/29/25. 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. The previously set 8/1/25 tracking status hearing is stricken and re-set to 10/3/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

CERTIFICATE of Service by Keith A. Vogt on behalf of Elizabeth's Studio LLC regarding terminate deadlines and hearings, set deadlines/hearings, 42

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeffrey I Cummings on 8/27/2025. Mailed notice