2025-cv-14223

COMPLAINT filed by PRL USA Holdings, Inc., Ralph Lauren Corporation; Filing fee $ 405, receipt number AILNDC-24380914.

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Exhibit 3 regarding complaint 1

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by PRL USA Holdings, Inc., Ralph Lauren Corporation

Notice of Claims involving Trademarks by PRL USA Holdings, Inc., Ralph Lauren Corporation

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Marcella Deshonda Slay

CASE ASSIGNED to the Honorable Thomas M. Durkin. 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.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 4 is granted. Mailed notice.

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for temporary restraining order 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

DECLARATION of Alice Pang regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation Exhibit 3 regarding declaration 15

(Exhibit 3-1)

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for miscellaneous relief 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Additionally, to the extent Plaintiff also makes a motion for expedited discovery or for an order permitting electronic service of process, Plaintiff should submit a proposed order for that relief that is separate from the proposed order for the TRO and asset restraint. The proposed order for the TRO and asset restraint should name the relevant defendants directly in the order, without reference to Schedule A. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 12 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 17 is granted. Mailed notice.

SEALED ORDER Authorizing Expedited Discovery and Electronic Service of Process. Signed by the Honorable Thomas M. Durkin on 11/26/2025. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 11/26/2025. Mailed notice.

Registry Deposit Information Form by PRL USA Holdings, Inc., Ralph Lauren Corporation

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation

ATTORNEY Appearance for Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation by Jennifer Mary Younan

SURETY BOND in the amount of $ 7,000.00 posted by PRL USA Holdings, Inc., Ralph Lauren Corporation

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

MOTION by Plaintiffs PRL USA Holdings, Inc., Ralph Lauren Corporation for preliminary injunction

(Exhibit A)

MEMORANDUM by PRL USA Holdings, Inc., Ralph Lauren Corporation in support of motion for preliminary injunction 28

(Declaration of Marcella D. Slay)

SUMMONS Returned Executed by PRL USA Holdings, Inc., Ralph Lauren Corporation as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/5/2025, answer due 12/26/2025.

Declaration of Marcella D. Slay

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [28] is set for 12/10/2025 at 8:45 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin: Motion hearing held on 12/10/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 28 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibit 3 to the Complaint 3, Exhibits to the Declaration of Alice Pang 16, the Order Authorizing Expedited Discovery and Electronic Service of Process 22, and the TRO 23. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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_Terminate_Instructions.pdf. A telephone status hearing is set for 1/12/2026 at 9:15 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 12/10/2025. Mailed notice.

NEW PARTIES: dengzhoushiqidongdongshangmaoyouxiangongsi, HUNWENYIN, jiongyuanshangmao, KunMingHongWeiTaoShangMaoYouXianGongSi, Polo Pony Collection, Pony and Mallet, wuqi11, YLSMZJF, zhouwenchaogs, benja_7394, fashion_tina_liubo, tangmeiyan, embroidestiny.com, adam-factory and west42 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.