2025-cv-06388

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23594928.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

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

(Exhibit 2 to the Declaration of K. Kuhn)

Exhibit Memorandum in Support of Motion for Electronic Service and Expedited Discovery

Exhibit 1 to the Complaint

Exhibit Memorandum in Support of Renewed Motion for Electronic Service and Expedited Discovery

Exhibit Memorandum in Support of Second Renewed Motion for Electronic Service

Exhibit Memorandum in Support of Motion for Default and Default Judgment

EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Complaint regarding complaint, 1 Modified on 6/17/2025.

Exhibit 2 to the Complaint

(Exhibit 6 to the Complaint)

Exhibit 1 to the Declaration of K. Kuhn

(Declaration of Katherine M. Kuhn in Support of Motion for Electronic Service and Expedited Discovery)

Exhibit 2 to the Complaint

(Declaration of Katherine M. Kuhn in Support of Renewed Motion for Electronic Service and Expedited Discovery)

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

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

CIVIL Cover Sheet

Exhibit 3 to the Complaint

(Exhibit 2 to the Declaration of K. Kuhn)

Exhibit 3 to the Complaint

(Exhibit 1 to the Declaration of K. Kuhn)

Exhibit 1 to the Declaration of K. Kuhn

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

Exhibit 4 to the Complaint

Exhibit 4 to the Complaint

(Declaration of Liangjie Li in Support of Motion for Default and Default Judgment)

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 Modified on 6/17/2025.

Exhibit 5 to the Complaint

(Exhibit 5 to the Complaint)

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

(Exhibit 6 to the Complaint)

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

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

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

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

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 3). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MAILED copyright report to Registrar, Washington DC.

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

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for service by publication, 12 before Honorable LaShonda A. Hunt on 6/19/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff names 3 Defendants in this case. However, after reviewing the complaint 1 and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all Defendants. See Fed. R. Civ. P. 20(a)(2); Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). By 6/30/25, Plaintiff must either (a) file a supplemental memorandum that refers to specific facts alleged in its filings and provides citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper; or (b) file an amended schedule A with a subset of Defendants, along with an amended declaration that explains how each of these defendants is properly joined with each other and includes labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only. In addition, Plaintiff's motion to seal 4 was not noticed for presentment in accordance with this Court's case management procedures. All counsel is reminded to review and comply with all court procedures. For future reference, non-compliant motions may be summarily stricken. Nonetheless, the Court denies the motion 4. Plaintiff has not established exceptional circumstances that would provide any basis for sealing the names of associated defendants listed in its complaint and schedule A 2 or filed a temporary restraining order as indicated in its motion to seal 4. See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000) ("Many a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing."). Thus, the request to seal Plaintiff's schedule A 2 is denied. The Clerk of Court is directed, forthwith, to unseal Plaintiff's schedule A 2 and the exhibits to its motion to seal 5. Finally, Plaintiff's motion for electronic service and expedited discovery 12 is denied without prejudice to renewal once the joinder issue is resolved. The motion hearing set for 6/19/25 13 is hereby stricken. Mailed notice (gel,)

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against Dxfan and terminating The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

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

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for service by publication, 16 before Honorable LaShonda A. Hunt on 7/2/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's renewed motion for leave to conduct expedited discovery and electronic service 16 is granted in part and denied in part. The Court grants Plaintiff's request for expedited discovery as the Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. Plaintiff's request for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) is denied without prejudice. Plaintiff seeks authorization to effectuate service of process by email and electronic publication but has not yet shown that it has a reliable email address at which it may reach Defendant. Any renewed motion must include these details. The motion hearing set for 7/2/25 17 is stricken. If no other relief has been sought, Plaintiff is ordered to file a status report by 7/15/25 updating the Court on the progress of expedited discovery and proposed next steps in the case. Mailed notice (gel,)

ORDER AUTHORIZING EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 6/24/2025. Mailed notice (gel,)

STATUS Report in Compliance with Docket 18 by Hong Kong Leyuzhen Technology Co. Limited

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's status report 22 indicates that it has not yet received contact information for Defendant from a third-party but that a renewed motion or electronic service will be filed upon receipt of such information. Accordingly, by 7/30/25, Plaintiff must file a renewed motion for electronic service or, if the third-party still has not provided Defendant's contact information, a status report regarding next steps, including how Plaintiff intends to obtain Defendant's contact information and effectuate service. Mailed notice (gel,)

SUMMONS Issued (Court Participant) as to Defendant Dxfan

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

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for service by publication, 25 before Honorable LaShonda A. Hunt on 7/23/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's second renewed motion for electronic service 25 is granted. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with online marketplace defendants. Enter Order Authorizing Electronic Service of Process. Motion hearing set for 7/23/25 26 is stricken. A status report regarding next steps is due by 8/22/25, if other appropriate relief has not been sought by that date. Mailed notice.

ORDER Authorizing Leave to Conduct Electronic Service. Signed by the Honorable LaShonda A. Hunt on 7/18/2025. Mailed notice.

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to Dxfan on 7/21/2025, answer due 8/11/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to Defendant Dxfan

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, 30 before Honorable LaShonda A. Hunt on 8/26/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for default and default judgment 30 is granted in part as to the request for entry of default. Plaintiff has shown that Defendants Dxfan was served on 7/21/25 and failed to plead or otherwise defend this action by 8/11/25 29. Accordingly, pursuant to Federal Rule of Civil Procedure 55(a), default is entered against Defendant Dxfan. Plaintiff's motion is entered and continued as to the request for entry of a default judgment. Any objections to the motion for entry of default judgment are due by 8/20/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve a copy of this order on all defaulted Defendants within one business day of entry and promptly file proof of such service. The motion hearing set for 8/26/25 31 is stricken. Lastly, the Clerk of Court is directed, forthwith, update the case caption to reflect that the Defendant is "Dxfan." Mailed notice (gel,)

CERTIFICATE of Service in Compliance with Docket 32 by Joseph Wendell Droter on behalf of Hong Kong Leyuzhen Technology Co. Limited regarding order on motion for default judgment, terminate deadlines, 32

STATUS Report in Compliance with Docket 27 by Hong Kong Leyuzhen Technology Co. Limited