2025-cv-09278

COMPLAINT filed by Quan Ren, Kui Cao; Filing fee $ 405, receipt number AILNDC-23843665.

Exhibit 4

Exhibit 4

Exhibit 1

Exhibit 1

SEALED EXHIBIT by Plaintiffs Kui Cao, Quan Ren Exhibit 1 regarding complaint 1

Exhibit 5

Exhibit 5

Exhibit 2

Exhibit 2

SEALED EXHIBIT by Plaintiffs Kui Cao, Quan Ren Exhibit 2 regarding complaint 1

(Exhibit 6)

Exhibit 6

Exhibit 3

SEALED EXHIBIT by Plaintiffs Kui Cao, Quan Ren Exhibit 3 regarding complaint 1

Exhibit 4

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Schedule A

Exhibit 5

ATTORNEY Appearance for Plaintiffs Kui Cao, Quan Ren by Keaton David Smith

ATTORNEY Appearance for Plaintiffs Kui Cao, Quan Ren by Abby Marie Neu

ATTORNEY Appearance for Plaintiffs Kui Cao, Quan Ren by Shengmao Mu

ATTORNEY Appearance for Plaintiffs Kui Cao, Quan Ren by Michael Mitchell

ATTORNEY Appearance for Plaintiffs Kui Cao, Quan Ren by Ryan Evan Carreon

CIVIL Cover Sheet

MAILED patent report to Patent Trademark Office, Alexandria VA.

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Notice of Claims Involving Patents

MOTION by Plaintiffs Kui Cao, Quan Ren for Leave to File Certain Documents Under Seal

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 1). (qrtr,) (Text entry; no document attached.)

AMENDED complaint by Quan Ren, Kui Cao against The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Amended Complaint

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Exhibit 1: to Amended Complaint

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Exhibit 2: to Amended Complaint

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Exhibit 3: to Amended Complaint

MOTION by Plaintiffs Kui Cao, Quan Ren to seal document sealed document[19], sealed document[16], sealed document[18], sealed document[17]

NOTICE of Motion by Michael Mitchell for presentment of motion to seal document[20] before Honorable LaShonda A. Hunt on 8/20/2025 at 10:00 AM.

SEALED DOCUMENT by Plaintiffs Kui Cao, Quan Ren Schedule A to the Amended Complaint

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. Plaintiffs' have moved for leave to file certain documents under seal [3], namely: (1) "Plaintiffs' Exhibits [sic] 1 to the Complaint which contains Plaintiffs' Patent"; (2) Plaintiffs' Schedule A; and (3) "Plaintiff's [sic] Notice of Claims Involving Patents." (Dkt. [14], at 451). However, Plaintiffs also filed other documents entirely or partially under seal. For example, Plaintiffs filed a sealed "Exhibit 2" to the complaint [3], which includes images of Plaintiffs' product. Plaintiffs also filed "Exhibit 3" to the complaint [4], which ostensibly includes evidence of alleged infringement by defendants. And Plaintiffs redacted portions of their complaint [1] without requesting leave for such an obfuscation or filing an unredacted version under seal. Furthermore, like the initial motion [14], Plaintiffs' subsequent motion to seal additional documents [20] fails to set forth exceptional circumstances that would justify sealing the names of all defendants and documents pertaining to their alleged infringing activity, even temporarily. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 25 C 2937, 2025 WL 2299593 at *7 (N.D. Ill. Aug. 8, 2025) (Kness, J.). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any 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." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-568 (7th Cir. 2000). For those reasons, the motions to seal [14][20] are denied. The Clerk of Court is directed to unseal the documents filed at [2] [3] [4] [5], [13], [16],[17],[18],[19],[22] and to update the docket and caption to reflect that Defendant's name is "AilunUS." The motion hearing set for 8/20/25 [21] is stricken. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: The parties are ordered to file the form Scheduling Order for Patent Cases by 9/18/25. A template for the Order can be found in Appendix A to the Local Patent Rules. Parties should review the Local Patent Rules prior to completing the Scheduling Order. The Court will set further case management deadlines after reviewing the proposed schedule. Mailed notice (gel,)

MOTION by Plaintiffs Kui Cao, Quan Ren for temporary restraining order, Including a Temporary Injunction and Expedited Discovery

MEMORANDUM by Kui Cao, Quan Ren in support of motion for temporary restraining order[25]

DECLARATION of Quan Ren regarding memorandum in support of motion[26]

MOTION by Plaintiffs Kui Cao, Quan Ren for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Kui Cao, Quan Ren in support of motion for miscellaneous relief[28]

DECLARATION of Shengmao Mu regarding memorandum in support of motion[29], memorandum in support of motion[26]

NOTICE of Motion by Keaton David Smith for presentment of motion for temporary restraining order[25], motion for miscellaneous relief[28] before Honorable LaShonda A. Hunt on 8/27/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiffs' ex partemotion for a TRO and other relief [25] is denied without prejudice. Plaintiffs have not come close to meeting the exacting standards of Fed. R. Civ. P. 65(b) to warrant ex parte relief. At a minimum, the Court finds that the generic copy-and-paste declarations made mostly "upon information and belief" fall well short of providing "specific facts" to "clearly show that immediate and irreparable injury, loss or damage will result," and also fail to satisfy the certification requirement. Indeed, counsel attached over 200 pages of articles and other documents that do not demonstrate why notice cannot be provided to this defendant who has already been identified on the docket as "AilunUS." That is ample reason to deny this extraordinary request. See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A., No. 25 C 2937, 2025 WL 2299593 at *4-7 (N.D. Ill. Aug. 8, 2025) (Kness, J.) ("Given that any irreparable harm wrought by infringement can, as with more traditional forms of IP litigation, be addressed through preliminary injunctive relief following an adversarial proceeding, the use of Rule 65(b) to ensure an unimpeded path to a prejudgment asset restraint is unsound."). Plaintiffs may be allowed to seek discovery to assist with identifying defendant, but any such request must be presented in a separate motion. Finally, Plaintiffs' request for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [28] is denied without prejudice. Plaintiffs seek authorization to effectuate service of process by email and electronic publication but have not yet shown that they have a reliable email address at which they may reach defendant. Any renewed motion must be presented in its own motion after Plaintiffs have acquired these details. The motion hearing set for 8/27/25 [31] is stricken and the 9/18/25 scheduling order deadline [24] stands. Mailed notice.