2024-cv-12909

COMPLAINT for Trademark Infringement filed by XYZ Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-22849817.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

Exhibit 4 to the Complaint

Exhibit 5 to the Complaint

(Exhibit 6 to the Complaint)

SEALED EXHIBIT by Plaintiff XYZ Corporation Sealed Complaint for Trademark Infringement regarding complaint, 1

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff XYZ Corporation to seal for Leave to File Under Seal

Declaration of Katherine M. Kuhn ISO Motion to File Under Seal

(Exhibit 1 to the Declaration of K. Kuhn)

SEALED EXHIBIT by Plaintiff XYZ Corporation Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff XYZ Corporation to seal for Leave to File Under Seal 4

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff XYZ Corporation for leave to file excess pages for Motion for Temporary Restraining Order

MOTION by Plaintiff XYZ Corporation for temporary restraining order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION

Declaration of Katherine M. Kuhn ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn ISO Temporary Restraining Order

Declaration of Fang ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of Fang

Exhibit 2 to the Declaration of Fang

(Declaration of Jillian Sullivan ISO Motion for Temporary Restraining Order)

SEALED EXHIBIT by Plaintiff XYZ Corporation Temporary Restraining Order regarding MOTION by Plaintiff XYZ Corporation for temporary restraining order INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, EXPEDITED DISCOVERY, AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION 9

Declaration of Katherine M. Kuhn ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Fang ISO Motion for Temporary Restraining Order

Exhibit 1 to the Declaration of Fang

Exhibit 2 to the Declaration of Fang

(Declaration of Jillian Sullivan ISO Motion for Temporary Restraining Order)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by XYZ Corporation

SEALED EXHIBIT by Plaintiff XYZ Corporation regarding notification of affiliates pursuant to local rule 3.2 11

ATTORNEY Appearance for Plaintiff XYZ Corporation by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff XYZ Corporation by Shawn Anthony Mangano

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff XYZ Corporation by Gokalp Bayramoglu

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion to seal[4], motion for leave to file excess pages[8], motion for temporary restraining order, [9] before Honorable Charles P. Kocoras on 1/7/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion to exceed page limitation in Plaintiff's Motion for entry of a Temporary Restraining Order [8] is granted. Mailed notice. (jn,)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal [4] is granted.Mailed notice. (jn,)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and service of process by e-mail and/or electronic publication [9] is granted. Mailed notice. (jn,)

TEMPORARY Restraining Order. Signed by the Honorable Charles P. Kocoras on 12/20/2024. Mailed notice. (jn,)

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto (Text entry; no document attached.)

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MOTION by Plaintiff HONG KONG YU'EN E-COMMERCE CO. LTD. to deposit funds into Court Registry

Exhibit Registry Deposit Information Form

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's motion for leave to deposit the requested bond of $5,000 USD into the Court registry [23] is granted. Enter order. Mailed notice

ORDER Granting Plaintiff's Motion for Leave to Deposit Funds Into Court Registry Signed by the Honorable Charles P. Kocoras on 12/31/2024. Mailed notice

SURETY BOND in the amount of $ $5,000.00 posted by XYZ Corporation, HONG KONG YU'EN E-COMMERCE CO. LTD.

MOTION by Plaintiff HONG KONG YU'EN E-COMMERCE CO. LTD. for extension of time of TEMPORARY RESTRAINING ORDER

MEMORANDUM IN SUPPORT OF PLAINTIFFS FIRST MOTION TO EXTEND TEMPORARY RESTRAININ

Declaration of K. Kuhn in Support of Motion to Extend Temporary Restraining Orde

NOTICE of Motion by Katherine Marilyn Kuhn for presentment of extension of time, [27] before Honorable Charles P. Kocoras on 1/14/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's Motion to Extend Temporary Restraining Order [27] is granted. The Temporary Restraining Order is extended until 1/17/2025. Mailed notice

MINUTE entry before the Honorable Charles P. Kocoras: The presentment hearing noticed for 1/14/2025 is stricken with no appearance necessary. Mailed notice

SUMMONS Returned Executed by HONG KONG YU'EN E-COMMERCE CO. LTD. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A Hereto on 1/3/2025, answer due 1/24/2025.

MOTION by Plaintiff HONG KONG YU'EN E-COMMERCE CO. LTD. for preliminary injunction

Exhibit Memorandum ISO Motion for Entry of Preliminary Injunction

Declaration of Katherine M. Kuhn ISo Motion for Entry of Preliminary Injunction

Declaration of En Fang ISO Motion for Entry of Preliminary Injunction

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for preliminary injunction, [33] before Honorable Charles P. Kocoras on 1/14/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for preliminary injunction [33] is taken under advisement. Presentment hearing noticed for 1/14/2025 is stricken; Court will rule by mail. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Preliminary Injunction [33] is granted. The Clerk is directed to unseal Docket Nos. [2], [5], [10], and [12], and change the name of the Plaintiff on the docket and in the case caption from XYZ Corporation to Hong Kong Yu'En E-Commerce Co. Limited. Plaintiff shall add all defendant names to the docket within three (3) business days. A status report is due on 2/14/2025. Enter Preliminary Injunction Order. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Charles P. Kocoras on 1/13/2025. Mailed notice

NOTICE of Voluntary Dismissal by HONG KONG YU'EN E-COMMERCE CO. LTD. ONLY as to Defendants 3, 4, 5, 7, 9, 11 and 13

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff filed a notice of voluntary dismissal 38. Accordingly, the claims against the Defendants listed in the notice are dismissed with prejudice. Plaintiff did not add all defendant names to the docket as previously ordered 36. All Defendant names must be added to the docket by 2/5/2025. Mailed notice

NEW PARTIES: CanJIKI Storefront, CHANGMOO Storefront, WCMZJ Storefront, Dazajoo Womens Clothing, DreamFish Storefront, Tang Shen Storefront, zhoufen Co. ltd, Encouthre Storefront, Oplxuo Storefront, TMKBGHML Storefront, Yishen Clothing, Masrin Storefront, XILIFAN Storefront, Geai Co. ltd Storefront, sksloeg Storefront and BOMYJESK Storefront added to case caption. (Text entry; no document attached.)

NEW PARTIES: CFLVAEK Storefront added to case caption. (Text entry; no document attached.)

Terminating DreamFish Storefront, Masrin Storefront, Oplxuo Storefront, WCMZJ Storefront, zhoufen Co. ltd, CFLVAEK Storefront and Dazajoo Womens Clothing (Text entry; no document attached.)

MOTION by Attorney Shawn A. Mangano to withdraw as attorney for Hong Kong Yu'En E-Commerce Co. Limited. No party information provided

MINUTE entry before the Honorable Charles P. Kocoras: Motion to withdraw as attorney [40] is granted. Attorney Shawn Anthony Mangano terminated. Mailed notice.

STATUS Report IN COMPLIANCE WITH DKT NO. 36 by Hong Kong Yu'En E-Commerce Co. Limited.

NOTICE of Voluntary Dismissal by Hong Kong Yu'En E-Commerce Co. Limited. ONLY as to Defendants 12, 15, 16 and 17

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal [43], all claims against the Defendants listed in the notices, are dismissed without prejudice. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: The Court reviewed Plaintiff's status report [42]. An updated status report is due on 3/14/2025. The status report should state which defendants remain in the case. Mailed notice.

STATUS Report IN COMPLIANCE WITH DOCKET NO. 45 by Hong Kong Yu'En E-Commerce Co. Limited.

MINUTE entry before the Honorable Charles P. Kocoras: The Court reviewed Plaintiff's status report [46]. An updated status report is due on 4/7/2025. The status report should state which defendants remain in the case. Mailed notice.

MOTION by Plaintiff Hong Kong Yu'En E-Commerce Co. Limited. for default judgment as to the identified Schedule A Defendants

MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMEN

Declaration of K. Kuhn in Support of Motion for Entry of Default and Default Jud

Exhibit A to the Declaration of K. Kuhn

Declaration of E. Fang in Support of Motion

NOTICE of Motion by Joseph Wendell Droter for presentment of motion for default judgment, [48] before Honorable Charles P. Kocoras on 3/25/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for default judgment [48] is granted. Enter Final Default Judgment Order. Presentment hearing scheduled on 3/25/2025 is stricken. Civil case terminated. Mailed notice.

FINAL DEFAULT JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 3/20/2025. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA