2026-cv-00090

COMPLAINT for Patent Infringement filed by Shenzhen Peishi Advertising Media Co., Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-24550479.

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)

SEALED EXHIBIT by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. Complaint for Patent 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 Shenzhen Peishi Advertising Media Co., Ltd. to seal

Declaration of William R. Brees in Support of Plaintiff's Motion to Seal

Exhibit 1 to the Declaration of William R. Brees

(Exhibit 2 to the Declaration of William R. Brees)

SEALED EXHIBIT by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. Motion to File Under Seal regarding MOTION by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. to seal 4

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Peishi Advertising Media Co., Ltd.

ATTORNEY Appearance for Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. by William Brees

MAILED Patent request letter to counsel of record.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 1).

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 to file under seal 4 is granted. Mailed notice.

ATTORNEY Appearance for Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. by Nazly Aileen Bayramoglu

MOTION by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. for order of Expedited Discovery

Declaration of William R. Brees in Support of Plaintiff's Motion for Expedi

MOTION by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. for service by publication, Electronic Service

Declaration of William R. Brees in Support of Motion for Electronic Service of P

MOTION by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. for temporary restraining order

Declaration of Anisah Beaston in Support of Plaintiff's Motion for Temporar

Declaration of Xiaoling Chen in Support of Plaintiff's Motion for Temporary

SEALED EXHIBIT by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. Declaration of Anisah Beaston in Support of Plaintiff's Motion for Temporary Restraining Order regarding MOTION by Plaintiff Shenzhen Peishi Advertising Media Co., Ltd. for temporary restraining order [15]

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.

DECLARATION of Joseph W. Droter regarding text entry, [17] in support of Motion for Temporary Restraining Order in compliance with Docket No. 17

Exhibit 1 to the Declaration of Joseph W. Droter

MINUTE entry before the Honorable Thomas M. Durkin: Pursuant to the provisions of 28 USC 294(b). Mailed notice

MINUTE entry before the Honorable Georgia N. Alexakis: Upon reassignment of this matter, the Court sets the following deadlines: Initial status hearing is set for 4/2/2026 at 9:30 a.m. in person in Courtroom 1719. By 3/26/2026, the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report. The Court grants Plaintiff's motion for expedited discovery [13]. Plaintiff is directed to submit a proposed order reflecting that granted relief to this Court's proposed order inbox. With respect to Plaintiff's motion for electronic service, by 2/9/2026, Plaintiff is directed to file a supplement to its motion addressing Smart Study Co., Ltd v. Shenzhenshixindajixieyouxiangongsi, --- F.4th ---, 2025 WL 3672740 (2d Cir. Dec. 18, 2025) (concluding that the Hague Service Convention does not permit service on defendants in signatory countries and that electronic service on such defendants is improper under Federal Rule of Civil Procedure 4(f)). The Court denies Plaintiff's motion for a temporary restraining order [15]. Plaintiff may renew its motion, in its current or amended form, after consulting this Court's order in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025). Mailed notice.

ORDER AUTHORIZING EXPEDITED DISCOVERY Signed by the Honorable Georgia N. Alexakis on 2/4/2026. Mailed notice.

SUPPLEMENT to set deadlines/hearings, [20] in Compliance with Docket 20