2025-cv-05945

2025-cv-05945 Hong Kong Leyuzhen Technology Co. Limited v. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

Date :5/28/2025
BrandRotita
Court :Northen District of Illinois
Law FirmBayramoglu

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Date

Document

1

May 28, 2025

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23544054.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

2

May 28, 2025

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Complaint for Copyright Infringement regarding complaint, [1]

3

May 28, 2025

CIVIL Cover Sheet

4

May 28, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal

Declaration of Katherine M. Kuhn in Support of Motion for Leave to File Under Se

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

5

May 28, 2025

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [4]

6

May 28, 2025

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

7

May 28, 2025

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

8

May 28, 2025

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

9

May 28, 2025

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

10

May 28, 2025

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

May 28, 2025

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

11

May 29, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [4] is granted. Mailed notice.

12

May 29, 2025

MAILED Copyright report to Registrar, Washington DC

13

June 2, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

Exhibit Memorandum in Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn in Support of Motion for Electronic Service

14

June 2, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages for Temporary Restraining Order

15

June 2, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

Exhibit Memorandum in Support of Motion for Temporary Restraining Order

Declaration of Katherine M. Kuhn in Support of Motion for Temporary Restraining

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Temporary Restraining Order

16

June 3, 2025

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.

17

June 4, 2025

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiff has filed a motion for a temporary restraining order. Plaintiff's complaint seeks relief for unauthorized use of certain "Copyrighted Protected Images." Plaintiff's motion for a TRO, however, also makes allegations regarding unauthorized use of "Copyrighted Designs." And the motion seeks an injunction of "Defendants' reproduction, public display, and distribution of Plaintiff's Copyrighted Designs." R. 15-1 at 20. These "Copyrighted Designs" are not mentioned in the complaint. It is not clear to the Court what relevance the "Copyrighted Designs" have to claims of unauthorized use of the "Copyrighted Protected Images" alleged in the complaint. The motion for a TRO [15] is denied for that reason. Plaintiff's motion for service by publication and electronic service [13] is also denied considering it is not currently clear what claims Plaintiff intends to allege. Mailed notice.

18

June 17, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication RENEWED Motion and Electronic Service

Exhibit Memorandum in Support of Renewed Motion for Electronic Service

Declaration of Katherine M. Kuhn in Support of Renewed Motion for Electronic Ser

19

June 17, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages for RENEWED Motion for Temporary Restraining Order

20

June 17, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order RENEWED Motion

Exhibit Memorandum in Support of renewed Motion for Temporary Restraining Order

Declaration of Katherine M. Kuhn in Support of renewed Motion for Temporary Rest

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Renewed Motion for Temporary Restrainin

21

June 18, 2025

ORDER: For the reasons stated in the attached order, Plaintiff's motion 20 is denied in part and granted in part. The motion is denied in that the Court will not enter a temporary restraining order and asset restraint. The motion is granted in that Plaintiff has leave to take expedited discovery. The motion for electronic service 18 is granted. The motion for excess pages 19 is granted. Signed by the Honorable Thomas M. Durkin on 6/18/2025. Mailed notice.

22

July 11, 2025

SUMMONS Submitted (Court Participant) for defendant(s) The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

23

July 15, 2025

SUMMONS Issued (Court Participant) as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

24

July 30, 2025

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nazly Aileen Bayramoglu

25

Aug. 22, 2025

MINUTE entry before the Honorable Thomas M. Durkin: A written status report is due by 9/5/2025. Mailed notice.

26

Aug. 28, 2025

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A on 8/28/2025, answer due 9/18/2025.

27

Sept. 5, 2025

STATUS Report in Compliance with Docket 25 by Hong Kong Leyuzhen Technology Co. Limited

28

Sept. 9, 2025

MINUTE entry before the Honorable Thomas M. Durkin: A written status report is due by 10/9/2025, unless a motion for default is filed before then. Mailed notice.

29

Sept. 19, 2025

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 17 Defaulted Defendants

Exhibit Memorandum in Support of Motion for Default and Default Judgment

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Liangji Li in Support of Motion for Default and Default Judgment

30

Sept. 22, 2025

MINUTE entry before the Honorable Thomas M. Durkin: The 10/9/2025 status report deadline is vacated. A telephone hearing as to the motion for default judgment [29] is set for 9/29/2025 at 9:00 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.

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