2025-cv-08898

COMPLAINT filed by Milwaukee Electric Tool Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-23814132.

(Exhibit 1)

(Exhibit A)

Declaration Paragoso Declaration

CIVIL Cover Sheet

Exhibit 1

ATTORNEY Appearance for Plaintiff Milwaukee Electric Tool Corporation by Michael A. Hierl

Declaration Hierl Declaration

ATTORNEY Appearance for Plaintiff Milwaukee Electric Tool Corporation by William Benjamin Kalbac

Exhibit Hierl Exhibit 1

ATTORNEY Appearance for Plaintiff Milwaukee Electric Tool Corporation by Robert Payton Mcmurray

Exhibit Hierl Exhibit 2

ATTORNEY Appearance for Plaintiff Milwaukee Electric Tool Corporation by John Wilson

Exhibit Hierl Exhibit 3

ATTORNEY Appearance for Plaintiff Milwaukee Electric Tool Corporation by Elizabeth Aubree Miller

(Exhibit Hierl Exhibit 4)

MOTION by Plaintiff Milwaukee Electric Tool Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Milwaukee Electric Tool Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Milwaukee Electric Tool Corporation

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2). (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.)

NEW PARTIES: KShengu added to case caption.

MOTION by Plaintiff Milwaukee Electric Tool Corporation to transfer case

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 8 and motion to transfer case 11 are set for a telephonic motion hearing on 8/7/2025 at 9:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 8/7/2025. For the reasons stated on the record, Plaintiff's motion to transfer case 11 is taken under advisement. Plaintiff's motion for leave to file under seal 8 is granted. Telephonic status hearing set for 8/22/2025 at 9:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 8/22/2025. For the reasons stated on the record, Plaintiff's motion to transfer [11] is denied. The case will proceed in this Court. Telephonic status hearing set for 9/2/2025 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (650) 479-3207 and the access code is 1808131170. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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.

MOTION by Plaintiff Milwaukee Electric Tool Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Milwaukee Electric Tool Corporation for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Milwaukee Electric Tool Corporation in support of motion for temporary restraining order, 18

SEALED EXHIBIT by Plaintiff Milwaukee Electric Tool Corporation Exhibit 2 to Paragoso Declaration regarding memorandum in support of motion, 19

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 9/2/2025. For the reasons stated on the record, Plaintiff's motion to exceed page limitation 17 and ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 18 are granted. Enter Sealed Temporary Restraining Order. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 9/2/2025 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($1,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Telephonic status hearing set for 9/16/2025 at 10:00 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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 Modified on 9/3/2025.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 9/2/2025. Mailed notice

MOTION by Plaintiff Milwaukee Electric Tool Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Milwaukee Electric Tool Corporation in support of motion for preliminary injunction 23

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 23

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

SUMMONS Returned Executed by Milwaukee Electric Tool Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 9/10/2025, answer due 10/1/2025.

CERTIFICATE of Service by John Wilson on behalf of Milwaukee Electric Tool Corporation

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 23

SUMMONS Returned Executed by Milwaukee Electric Tool Corporation

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction 23 will be heard at the telephonic hearing set for 9/16/2025 at 10:00 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

Surety BOND in the amount of $ 1,000 posted by Milwaukee Electric Tool Corporation. (Document not Imaged)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 9/16/2025. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [23] is granted. By 9/23/2025, Plaintiff shall file a supplemental submission that reflects the amount of frozen funds for each defendant. Plaintiff is granted leave to file the document under seal. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A [9], (2) Exhibit 2 to Paragoso Declaration [20], and (3) the sealed temporary restraining order [22]. Plaintiff's counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Term inate_Instructions.pdf. Telephonic status hearing set for 10/16/2025 at 10:15 AM. The call-in number is (650) 479-3207 and the access code is 1808131170. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. 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

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 9/16/2025. Mailed notice