2025-cv-08037

2025-cv-08037 Edward Wargo v. The Partnerships and Unincorporated Associations Identified On Schedule A

Date :7/15/2025
Court :Northen District of Illinois
Law FirmKeith

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Date

Document

1

July 15, 2025

COMPLAINT filed by Edward Wargo; Filing fee $ 405, receipt number AILNDC-23753193.

(Exhibit 1)

2

July 15, 2025

SEALED DOCUMENT by Plaintiff Edward Wargo Schedule A to the Complaint 1

3

July 15, 2025

CIVIL Cover Sheet

4

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Keith A. Vogt

5

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Yanling Jiang

6

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Yi Bu

7

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Adam Grodman

8

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Cameron Eugene Mcintyre

9

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Monica Rita Martin

10

July 15, 2025

ATTORNEY Appearance for Plaintiff Edward Wargo by Christopher Romero

July 15, 2025

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable M. David Weisman. 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: MingZ Fashion added to case caption.

NEW PARTIES: zhouxinshangmao us, guangxibangtuoxinxikejiyouxiangongsi, VIVIHOME, CHUNZHANG, yilingquyaquelingzhenfanngbaihuodian getigongshanghu, xiaoxue-, Zhaochenlu, SOJAWA and XUEKLINGBAI added to case caption.

NEW PARTIES: JBGJWL, jinyankgt, Tingtingfang, ZSSZO, YIYIXIANG, JINDOUDOU, lichengjutoukuajing, Taphome, LIZIMI, yearnjear, SHElifestyle, Yeer Co., MYS QiQi, Aeyadis, NiuMiao563, Huanjun886, caozhongliang, ShangHaiDingJiZhuangShiGongChengZhongXin, jingmenshigangyoushangmao, Caoyucn, gedcnja, Muxxirt US, OMGA-SHOP, kaishengshop, pinzhmen, azkiju, ABADANEE and jinjianhui added to case caption.

NEW PARTIES: CXHZBHD, chunguiyiding668, Fan shi si Department Store, ushiechengquzelinz, kenzi77, lichaoqwe, Yingyoung, Defendant 13, Defendant 39, Defendant 42, Defendant 47 and Defendant 49 added to case caption.

11

July 16, 2025

MAILED copyright report to Registrar, Washington DC

12

July 17, 2025

SEALED DOCUMENT by Plaintiff Edward Wargo Amended Schedule A to the Complaint 1 and Schedule A 2

13

July 17, 2025

MOTION by Plaintiff Edward Wargo for leave to file under seal

14

July 17, 2025

MOTION by Plaintiff Edward Wargo for leave to file excess pages

16

July 17, 2025

MEMORANDUM in support of 15 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Edward Wargo

(Exhibit 1, of Edward Wargo's declaration)

17

July 17, 2025

SEALED EXHIBIT by Plaintiff Edward Wargo Sealed Exhibit 2, Declaration of Edward Wargo regarding memorandum in support of motion, 16

(Exhibit 2-1)

18

July 23, 2025

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal [13], motion for leave to file excess pages [14], 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 [15] are granted as to the defendants listed in 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 9/22/25 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice

23

July 29, 2025

MOTION by Plaintiff Edward Wargo for preliminary injunction

24

July 29, 2025

MEMORANDUM by Edward Wargo in support of motion for preliminary injunction 23

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

25

July 29, 2025

SUMMONS Returned Executed by Edward Wargo as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/29/2025, answer due 8/19/2025.

(Declaration of Service, Keith A. Vogt)

26

Aug. 6, 2025

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 23. 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 August 15, 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. (jn,)

27

Aug. 6, 2025

CERTIFICATE of Service by Keith A. Vogt on behalf of Edward Wargo regarding text entry, 26

28

Aug. 19, 2025

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

29

Aug. 27, 2025

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 23 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 the remaining defendants by 9/2/25. Plaintiff's counsel is directed to ensure that all remaining 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. If plaintiff intends to move for default judgment as to any remaining defendants, any such motion shall be filed by 9/30/25. The 9/22/25 tracking status hearing is stricken and re-set to 10/31/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

30

Aug. 29, 2025

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Jeffrey I Cummings on 8/29/2025. Mailed notice

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