2025-cv-08425

COMPLAINT filed by Chengliang Wang; Filing fee $ 405, receipt number AILNDC-23783874.

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiff Chengliang Wang trademark registration regarding complaint 1

SEALED EXHIBIT by Plaintiff Chengliang Wang Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiff Chengliang Wang Genuine Listing regarding complaint 1

ATTORNEY Appearance for Plaintiff Chengliang Wang by Zhiwei Hua

CIVIL Cover Sheet

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Georgia N Alexakis for all further proceedings pursuant to Local Rule 28:294(b). Mailed notice

(Request for Reassignment)

MOTION by Plaintiff Chengliang Wang for temporary restraining order and expedited discovery

DECLARATION of ZHIWEI HUA regarding motion for temporary restraining order 7 and expedited discovery

Exhibit 1 to Declaration

Exhibit 2 to Declaration

Exhibit 3 to Declaration

Exhibit 4 to Declaration

(Exhibit 5 to Declaration)

SEALED DOCUMENT by Plaintiff Chengliang Wang Declaration of Owner in Support of Motion for TRO and Expedited Discovery

SEALED EXHIBIT by Plaintiff Chengliang Wang regarding sealed document 9, MOTION by Plaintiff Chengliang Wang for temporary restraining order and expedited discovery 7

Exhibit trademark registration

Exhibit Schedule B part 1

Exhibit Schedule B part 2

(Exhibit Schedule B part 3)

MOTION by Plaintiff Chengliang Wang for leave to file under seal

MOTION by Plaintiff Chengliang Wang Electronic Service of Process Pursuant to FRCP 4(f)(3)

Declaration of Hua in Support of Motion for Electronic Service

Exhibit 1 of Hua's Declaration

(Exhibit 2 of Hua's Declaration)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion for leave to file certain documents under seal 11. Upon review of the complaint, the Court sua sponte raises the propriety of joining 95 defendants in a single action. By 8/14/25, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of this Court's orders in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagram International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). In the alternative, plaintiff has leave to file an amended complaint by 8/14/25 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. The Court denies plaintiff's motions for a temporary restraining order 7 and electronic service of process 12 without prejudice to renewal after the Court's joinder concerns have been addressed. No motion for an ex parte temporary restraining order should be re-filed in this matter without counsel first consulting this Court's order in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025).

MINUTE entry before the Honorable Georgia N. Alexakis: Initial status hearing is set for 10/6/25 at 9:30 a.m. in person in Courtroom 1719. By 9/29/25, the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

MEMORANDUM by Chengliang Wang in support to Joinder

MINUTE entry before the Honorable Georgia N. Alexakis: The Court has reviewed plaintiff's memorandum regarding joinder 18 and determines that plaintiff has failed to satisfy its burden to show that joinder of 95 defendants is proper under Federal Rule of Civil Procedure 20. See Estee Lauder Cosms. Ltd. v. The Partnerships, 334 F.R.D. 182, 185 (N.D. Ill. 2020) ("[plaintiff] bears the burden of demonstrating that joinder is proper"). In so concluding, the Court adopts its analyses in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagram International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). Although the Court specifically directed plaintiff to these prior decisions 16, plaintiff's joinder memorandum does not cite them, let alone address their reasoning. According to plaintiff, joinder of 95 defendants is proper because all defendants sell their products on Amazon; all sell "the same category of goods," which is "stuffed toys"; all use plaintiff's mark in their product titles; and all use generic, unregistered brand names to conceal their identities and avoid liability. 18 at 3. These rationales for joinder are ones that the Court already addressed, and rejected, in Anagram International and Bug Art Limited. See also Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 at 23 (N.D. Ill. Nov. 18, 2024) ("Even if the t-shirts came from the same factory, and even if the unauthorized vendors employed the same hustle, I would have a hard time establishing a connection between a vendor in Chicago and a vendor in Los Angeles even though they fit a particular profile."). Plaintiff is ordered to show cause in writing by 8/22/25 why this case should not be dismissed.

NOTICE of Voluntary Dismissal by Chengliang Wang

MINUTE entry before the Honorable Georgia N. Alexakis: Per plaintiff's notice of voluntary dismissal 20, pursuant to Federal Rule of Civil Procedure 41(a)(1), this case is dismissed without prejudice. Civil case terminated.

MAILED Trademark report with certified copy of minute order dated 8/13/2025 to Patent Trademark Office, Alexandria VA