2025-cv-12965

COMPLAINT filed by SS Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-24247674.

Schedule A

Ex.1

Ex.2

(Ex.3)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff SS Inc. by Ying Chen

MOTION by Plaintiff SS Inc. for leave to file documents under seal

NEW PARTIES: SS Inc. added to case caption. Terminating SS Inc.

SEALED DOCUMENT by Plaintiff SS Inc. Unredacted Complaint

Schedule A

(Ex.1)

CASE ASSIGNED to the Honorable Sunil R. Harjani. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2). (qrtr,)

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. (qrtr,)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for leave to file under seal 4 is granted as to the request to file certain documents under seal and denied as to the request to proceed anonymously and to redact Plaintiff's intellectual property and brand information. Exceptional circumstances have not been shown to proceed anonymously. See Fed. R. Civ. P. 10(a) ("The title of the complaint must name all the parties[.]"); Doe v. Village of Deerfield, 819 F.3d 372, 377 (7th Cir. 2016) ("To proceed anonymously, a party must demonstrate 'exceptional circumstances' that outweigh both the public policy in favor of identified parties and the prejudice to the opposing party that would result from anonymity."); XYZ Corp. v. Partn. & Unincorporated Ass'ns Identified on Schedule A, 2020 WL 6681360, at *1 (N.D. Ill. Nov. 12, 2020) ("No-name litigation is the rare exception, not the Rule."). "There is insufficient evidence. that Schedule A defendants are taking advantage of the case-tracking option to such an extent that it is materially impeding brand owners' enforcement efforts." XYZ Corp. v. Partn. & Unincorporated Ass'ns Identified on Schedule A, 2022 WL 180151, at *2 (N.D. Ill. Jan. 20, 2022). Accordingly, by 10/30/2025, plaintiff shall file an amended complaint that lists plaintiff's true name. Moreover, upon review of the complaint the Court sua sponte raises the proprietary of joinder of 296 defendants in this case. See, e.g., Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). By 10/30/2025, 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 single defendant or 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. Mailed notice

MOTION by Plaintiff SS Inc. for leave to file Documents Under Seal

AMENDED complaint by SS Inc. against JOHN DOE and terminating The Partnerships and Unincorporated Associations Identified in Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff SS Inc. Unredacted Amended Complaint

MINUTE entry before the Honorable Sunil R. Harjani: By 11/7/2025, Plaintiff shall file a status report with an update on this case. Mailed notice

STATUS Report by SS Inc.

MINUTE entry before the Honorable Sunil R. Harjani: By 11/20/2025, Plaintiff shall file a status report with an update on the case. Mailed notice

SEALED MOTION by Plaintiff SS Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Alternative Service

Brief In Support of Motion

Declaration of Plaintiff

Ex. 1

(Ex.2)

STATUS Report by SS Inc.

MINUTE entry before the Honorable Sunil R. Harjani: By close of business on 11/25/2025, Plaintiff shall submit a proposed order for entry of a temporary restraining order to the Court's proposed order inbox. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for leave to file under seal [9], and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and alternative service of process [15] are granted. Plaintiff's submissions establish that were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that 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. Further, 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 products, 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 at 3:15 p.m. on 12/2/2025. Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) if appropriate no later than 12/9/2025. Telephone status hearing is set for 12/16/2025 at 9:15 a.m. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Sunil R. Harjani on 12/2/2025. Mailed notice

MOTION by Plaintiff SS Inc. for preliminary injunction as to Defendant techeso

MEMORANDUM by SS Inc. in support of motion for preliminary injunction[20]

Declaration of James Judge

SUMMONS Submitted (Court Participant) for defendant(s) by Plaintiff SS Inc.