Intercontinental Great Brands, LLC v. The Partnerships and Unincorporated Associations Identified On Schedule A

COMPLAINT (Redacted) filed by Intercontinental Great Brands, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23564423.

(Exhibit Exhibit 2 to the Redacted Complaint)

EXHIBIT 1 by Plaintiff Intercontinental Great Brands, LLC Exhibit 1 to the Redacted Complaint (Main Document 2 replaced on 12/11/2025). Modified on 12/11/2025.

SCHEDULE A by Plaintiff Intercontinental Great Brands, LLC Schedule A to the Redacted Complaint (Main Document 3 replaced on 12/11/2025). Modified on 12/11/2025.

CIVIL Cover Sheet

COMPLAINT (Unredacted) by Plaintiff Intercontinental Great Brands, LLC Complaint (Unredacted). Modified on 12/11/2025.

Exhibit Exhibit 1 to the Unredacted Complaint

Exhibit Exhibit 2 to the Unredacted Complaint

(Exhibit Schedule A to the Unredacted Complaint) (Main Document 5 replaced on 12/11/2025). (Attachment 1 replaced on 12/11/2025). (Attachment 2 replaced on 12/11/2025). (Attachment 3 replaced on 12/11/2025)

NOTICE of Trademark Claim by Plaintiff Intercontinental Great Brands, LLC Notice of Trademark Claim (Main Document 6 replaced on 12/11/2025). Modified on 12/11/2025.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Intercontinental Great Brands, LLC

MOTION by Plaintiff Intercontinental Great Brands, LLC to seal document sealed document, 5, sealed document 2, sealed document 6

ATTORNEY Appearance for Plaintiff Intercontinental Great Brands, LLC by Brandon Matthew Beymer

ATTORNEY Appearance for Plaintiff Intercontinental Great Brands, LLC by Daliah Saper

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

MOTION by Plaintiff Intercontinental Great Brands, LLC for temporary restraining order

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for temporary restraining order 11 (Redacted)

MEMORANDUM in support of motion for temporary restraining order 11 (Unredacted) by Plaintiff Intercontinental Great Brands, LLC (Main Document 13 replaced on 12/11/2025). Modified on 12/11/2025.

DECLARATION of Plaintiff in Support of Motion for Temporary Restraining Order by Plaintiff Intercontinental Great Brands, LLC. Modified on 12/11/2025.

Exhibit Exhibit 1

Exhibit Exhibit 2

Exhibit Exhibit 3A

Exhibit Exhibit 3B

Exhibit Exhibit 3C

Exhibit Exhibit 3D

Exhibit Exhibit 3E

Exhibit Exhibit 3F

(Exhibit Exhibit 3G) (Main Document 14 replaced on 12/11/2025). (Attachment 1 replaced on 12/11/2025). (Attachment 2 replaced on 12/11/2025). (Attachment 3 replaced on 12/11/2025). (Attachment 4 replaced on 12/11/2025). (Attachment 5 replaced on 12/11/2025). (Attachment 6 replaced on 12/11/2025). (Attachment 7 replaced on 12/11/2025). (Attachment 8 replaced on 12/11/2025). (Attachment 9 replaced on 12/11/2025)

MOTION by Plaintiff Intercontinental Great Brands, LLC for service by publication

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for service by publication 15

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. Plaintiff's motion for leave to file under seal 8 is granted. However, plaintiff's motion for temporary restraining order 11, and plaintiff's motion for electronic service of process 15 are entered and continued generally. Upon review of the complaint and the TRO submissions, the Court sua sponte raises the proprietary of joinder of over 100 defendants in this case. See, e.g. Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D.Ill. 2020). By 8/1/25, plaintiff shall file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. In the alternative, plaintiff has leave to file an amended complaint with a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Estee Lauder, 334 F.R.D. at 189. Tracking status hearing set for 8/29/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

First AMENDED complaint by Intercontinental Great Brands, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A (Redacted)

Exhibit Exhibit 3 to the Redacted First Amended Complaint

(Exhibit Redline Copy of the Redacted First Amended Complaint)

EXHIBIT 1 to the Redacted First Amended Complaint by Plaintiff Intercontinental Great Brands, LLC (Main Document 21 replaced on 12/11/2025). Modified on 12/11/2025.

EXHIBIT 2 to the Redacted First Amended Complaint by Plaintiff Intercontinental Great Brands, LLC. Modified on 12/11/2025.

Exhibit Exhibit 2A to the Redacted First Amended Complaint

Exhibit Exhibit 2B to the Redacted First Amended Complaint

(Exhibit Exhibit 2C to the Redacted First Amended Complaint) (Main Document 22 replaced on 12/11/2025). (Attachment 1 replaced on 12/11/2025). (Attachment 2 replaced on 12/11/2025). (Attachment 3 replaced on 12/11/2025)

SCHEDULE A to the Redacted First Amended Complaint by Plaintiff Intercontinental Great Brands, LLC (Main Document 23 replaced on 12/11/2025). Modified on 12/11/2025.

FIRST AMENDED COMPLAINT (Unredacted) by Plaintiff Intercontinental Great Brands, LLC. Modified on 12/11/2025.

Exhibit Exhibit 1 to the Unredacted First Amended Complaint

Exhibit Exhibit 2A to the Unredacted First Amended Complaint

Exhibit Exhibit 2B to the Unredacted First Amended Complaint

Exhibit Exhibit 2C to the Unredacted First Amended Complaint

Exhibit Exhibit 3 to the Unredacted First Amended Complaint

Exhibit Schedule A to the Unredacted First Amended Complaint

(Exhibit Redline Copy of the Unredacted First Amended Complaint) (Main Document 24 replaced on 12/11/2025). (Attachment 1 replaced on 12/11/2025). (Attachment 2 replaced on 12/11/2025). (Attachment 3 replaced on 12/11/2025). (Attachment 4 replaced on 12/11/2025). (Attachment 5 replaced on 12/11/2025). (Attachment 6 replaced on 12/11/2025). (Attachment 7 replaced on 12/11/2025)

MINUTE entry before the Honorable Jeffrey I Cummings: On 7/14/25, the Court sua sponte raised the issue of joinder of over 100 defendants in this case 19 and directed plaintiff to file a supplemental brief regarding joinder. Alternatively, the Court granted plaintiff leave to file an amended complaint with a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Here, while plaintiff filed an amended complaint (now including over 80 defendants), it failed to file the accompanying memorandum explaining the proprietary of joinder of the defendants in the amended schedule A. Plaintiff shall file the memorandum on or before 10/3/25. The previously set 8/29/25 tracking status hearing is stricken and re-set to 10/27/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: On 7/14/25, the Court sua sponte raised the issue of joinder of over 100 defendants in this case 19 and directed plaintiff to file a supplemental brief regarding joinder. Alternatively, the Court granted plaintiff leave to file an amended complaint with a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Here, while plaintiff filed an amended complaint (now including over 80 defendants), it failed to file the accompanying memorandum explaining the proprietary of joinder of the defendants in the amended schedule A. Plaintiff shall file the memorandum on or before 10/3/25. The previously set 8/29/25 tracking status hearing is stricken and re-set to 10/27/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MEMORANDUM text entry, 26 by Intercontinental Great Brands, LLC in Support of Joinder

(Exhibit Exhibit A)

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiff's memorandum in support of joinder 27 and finds that joinder is proper at this preliminary stage pursuant to Fed.R.Civ.P. 20(a)(2). Plaintiff has submitted evidence establishing that beyond just infringing the same trademark, which alone is insufficient to establish the propriety of joinder, see Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182, 187 (N.D.Ill. 2020), (1) defendants, all located in China, appear to buy product from the same seller (Changsha X Being Importing & Exporting Co., Ltd.); (2) all defendants use the keyword "Taba" as their branding and offer identical products for sale; (3) out of 52 purchases received, all 52 consist of similar or identical products; and (4) 79% of defendants use common photos (which do not belong to the plaintiff). Further, no defendants will be prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D.Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. And, of course, the Court's finding regarding joinder in this case is not dispositive of the propriety of joinder in any other cases before the Court. Plaintiff's previously filed motion for TRO 11 and for electronic service of process 15 (directed at the original Schedule A defendants) are terminated as moot, and plaintiff is granted leave to file renewed motions directed only at the amended Schedule A defendants. The 10/27/25 tracking status hearing is stricken and reset to 11/21/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MOTION by Plaintiff Intercontinental Great Brands, LLC for temporary restraining order

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for temporary restraining order 29 (Redacted)

MEMORANDUM in support of motion for temporary restraining order 29 (Unredacted) by Plaintiff Intercontinental Great Brands, LLC (Main Document 31 replaced on 12/11/2025). Modified on 12/11/2025.

MOTION by Plaintiff Intercontinental Great Brands, LLC for service by publication

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for service by publication 32

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 30, and motion for electronic service of process 32 are granted as to Amended Schedule A. Plaintiff's submissions establish that were defendants to be informed of this proceeding before a TRO could issue, 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. Mailed notice

TEMPORARY RESTRAINING ORDER signed by the Honorable Jeffrey I Cummings on 10/24/2025. (ags) (Main Document 35 replaced on 12/11/2025). Modified on 12/11/2025.

SURETY BOND in the amount of $ 10,000 posted by Intercontinental Great Brands, LLC (Document not scanned).

MOTION by Plaintiff Intercontinental Great Brands, LLC for extension of time to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the TRO 37 is granted. The TRO entered on 10/24/25 is extended to 11/21/25. Mailed notice

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 37 "UOOZII OFFICIAL"

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (qrtr,)

MOTION by Plaintiff Intercontinental Great Brands, LLC for preliminary injunction

(Exhibit Schedule A)

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for preliminary injunction 42

SUMMONS Returned Executed by Intercontinental Great Brands, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/14/2025, answer due 12/5/2025.

(Declaration Declaration of Service)

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 66 "ezowmn6"

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 42. 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 December 2, 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. The 11/21/25 tracking status hearing is stricken and reset to 12/22/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

DECLARATION of Brandon Beymer regarding terminate deadlines and hearings, set deadlines/hearings, 46 Declaration of Service of Dkt No. 46 on Defendants

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 80 "xuyouyou"

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 43 "Hsswork"

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 82 "Xlaughing"

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 30 "Atneway"

ATTORNEY Appearance for Defendant SHILIFE by Zhongyi Huang

MOTION by Defendant SHILIFE for extension of time (Unopposed)

MINUTE entry before the Honorable Jeffrey I Cummings: Defendant Shilife's unopposed motion for extension of time 53 is granted. If this matter is not resolved, defendant Shilife shall answer or otherwise plead by 12/26/25. Mailed notice

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 33 "FeiChengming Technology Co., LTD"

STIPULATION of Dismissal for Defendant 47 "SHILIFE"

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 79 "FuGuang94"

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff and defendant 47 ("Shilife") have filed a joint stipulation of dismissal 35, which is self-effectuating under Rule 41(a)(1)(A)(ii). Pursuant to that stipulation, plaintiff's claims against defendant 47 (Shilife) are dismissed with prejudice. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 42 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. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all 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 an order of default and default judgment, plaintiff shall file its motion on or before 1/16/26. The 12/22/25 tracking status hearing is stricken and re-set to 2/9/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Jeffrey I Cummings on 12/10/2025. Mailed notice

NEW PARTIES: Shenzhen Yihong Bo Electronic Technology Co.Ltd, Qingdao Fidget Toy Co., Ltd, Qingdao Pretty International Trade Co., Ltd., Changsha X Being Importing & Exporting Co.,ltd, Xuzhou Jixingcheng Crafts Co., Ltd, Yiwu Children's Companion Clothing Co., Ltd., Baby Enlightenment Store, Department Dropshipping Store, Wumart toy factory store Store, KK Smart Toy Store, Dolls & Accessories Store, Dream Factory Toy Store, Shop1103904067 Store, Wang Chaun Lung Store, Ali-Ciu Store, PPmink Toy Store, Professional Selling Store, Shop1104108716 Store, Shop1104165338 Store, LMischievous Baby Store, Exquisite Baby Toys Store, Shop1104277132 Store, PYYQTGJJ-3 Store Store, zhuhaishixiqimaoyizhongxin, kunxianshangmao, ElegancePlus Squishy, neimengguyoukunshangwuyouxiangongsi, MiLiShuZ, yiruikeji2024, xuzhoushitangleshangmaoyouxiangongsi, Sinikoro, foshanshimengkexunshangmaohang, BHNJUTM, liangjuanmaoyi, Xin-Zhen, rongtong department store, AYCYJFFA, Bright Ocean, Xiamenshishoulinfangdianzishangwudian, Lamb's shop, KaiQianShangMao, hxyzz, StardustEmporium, Wu'an Taijin Trading Co., Ltd., FEICHIZHONG, foshanshijiuxiqichexiaoshoufuwuyouxiangongsi, Zenfro, YURONGMINSHOP, CuiTby, ZHUNASHANGMAO, Thriving little shop, diaodan678, gratel, xpreal, green9696, time_brocade, time_brocade1, wenxin_pavilion1, czhrfzkj, dangeranfang, jiyuandianzishangsha, merkuriki, pannio, shanghaioufengguangs0, wbofficial, yuantiao20150317, Finger Yn, Rose shop, FAST SHOP, jinanfengyanzhaohe, zhanghaipengdahai, JUNJUN SHOP and MaJoJaoy added to case caption.

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 12/31/2025: Mailed notice.

MOTION by Plaintiff Intercontinental Great Brands, LLC for entry of default, MOTION by Plaintiff Intercontinental Great Brands, LLC for default judgment as to the Defendants on the redacted Schedule A

(Exhibit Schedule A)

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for entry of default, motion for default judgment, 62

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 62 for entry of default and default judgment against all defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 1/29/26. 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. The 2/9/26 tracking status hearing is stricken and reset to 2/27/26 at 9:00 a.m. (to track the case only, no appearance is required). Notice mailed by Judge's staff

DECLARATION of Brandon Beymer regarding terminate deadlines and hearings, set deadlines/hearings, 64 Declaration of Service of Dkt No. 64 on Defendants

NOTICE of Voluntary Dismissal by Intercontinental Great Brands, LLC for Defendant 29 "yiruikeji2024"

Order on Motion for Entry of Default

Order

Judgment - AO450