2025-cv-07913

COMPLAINT filed by Revelyst Operations LLC ; Filing fee $ 405, receipt number AILNDC-23742468.

Ex. 1 - Reg. Certificates

Ex. 2 - CBP

Ex. 3 - IP Rights

(Ex. 4 - DHS)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff Revelyst Operations LLC - Schedule A - regarding complaint 1

MOTION by Plaintiff Revelyst Operations LLC to seal document exhibit 3

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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 trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Peter Krusiewicz

MINUTE entry before the Honorable John Robert Blakey: Plaintiff seeks to sue 47 separate Defendants in this single trademark infringement suit, see 1, 2. Joinder of multiple defendants in a single infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). In this regard, Plaintiff alleges that "Even though Defendants operate under multiple fictitious names, there are numerous similarities among the Defendant Internet Stores. For example, some or all of the Defendant Internet Stores use substantially identical or equivalent language and/or imagery to sell Infringing Products," and that "the Infringing Products for sale in the Defendant Internet Stores bear similarities and indicia of being related to one another, suggesting that the Infringing Products were manufactured by and come from a common source and that, upon information and belief, certain Defendants are interrelated." 1 21, 22. Plaintiff also alleges that "Many of the Defendants' storefronts include other notable common features, including common payment methods, lack of contact information, identically or similarly 1 appearing products, identical or similarly priced items and volume sales discounts, and the use of similar text and/or images. For some Defendants, these commonalities suggest potential common ownership or coordination." Id. 24. But these allegations remain conclusory and unsupported by Plaintiff's submissions and also fail to support the joinder of ALL named Defendants. Because Plaintiff has failed to demonstrate the propriety of joining all Defendants in this single suit, the Court dismisses the complaint without prejudice. If Plaintiff can, consistent with its obligations under Rule 11, amend its complaint to allege facts to support the joinder of all Defendants in this single action, it may do so by 8/1/25. If Plaintiff fails to comply, the Court will dismiss this case. The Court grants Plaintiff's motion for leave to file under seal 4, and Plaintiff may file any amended complaint under seal as well. Mailed notice.

AMENDED complaint by Revelyst Operations LLC 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

(- Amended Schedule A -)

MOTION by Plaintiff Revelyst Operations LLC for Expedited Discovery and Electronic Service

Declaration of Matthew A. Werber

Exhibit A - Amazon.com pages

Exhibit B - Hague

Exhibit C - Temu

(Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief, 10 before Honorable John Robert Blakey on 8/6/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Plaintiff initially filed a complaint seeking to sue 47 separate defendants in this single trademark infringement suit, see 1, 2, but has now filed an amended complaint against just one Defendant. See 9, [9-5]. The complaint avoids any joinder issues but remains drafted as if it still targets multiple Defendants (so too Plaintiff's motion for expedited discovery and the accompanying proposed order). Given the disconnect and ambiguity, the Court dismisses Plaintiff's amended complaint 9, denies without prejudice Plaintiff's motion 10, and strikes the 8/6/25 Notice of Motion date. If Plaintiff wishes to proceed, it must conform its allegations to the current Schedule A to make clear that it is asserting claims against a single defendant. Mailed notice.

SECOND AMENDED complaint by Revelyst Operations LLC 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

(- Amended Schedule A -)

MOTION by Plaintiff Revelyst Operations LLC SECOND MOTION FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE

Declaration of Matthew A. Werber

Exhibit A - Amazon Pages

Errata B - Hague

Exhibit C - Temu

(Unpublished)

NOTICE of Motion by Matthew A. Werber for presentment of motion for miscellaneous relief, 14 before Honorable John Robert Blakey on 8/20/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's submissions, the Court grants Plaintiff's motion for leave to conduct expedited discovery and for electronic service of process 14 and strikes the 8/20/25 Notice of Motion date. Enter Order. Mailed notice.

ORDER Granting Leave for Expedited Discovery and Electronic Service. Signed by the Honorable John Robert Blakey on 8/19/2025. Mailed notice.

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