Paddington & Company Ltd. v. The Partnerships and Unincorporated Associations Identified On Schedule A

COMPLAINT filed by Paddington & Company Ltd. ; Filing fee $ 405, receipt number AILNDC-24701736.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Paddington & Company Ltd. Schedule A regarding complaint[1]

MOTION by Plaintiff Paddington & Company Ltd. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Paddington & Company Ltd.

Notice of Claims Involving Trademarks by Paddington & Company Ltd.

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Alexander Whang

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Elizabeth Jewell Banegas

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. 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.

AMENDED complaint by Paddington & Company Ltd. against The Partnerships and Unincorporated Associations Identified On Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Paddington & Company Ltd. Schedule A regarding amended complaint[13]

MOTION by Plaintiff Paddington & Company Ltd. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief[15]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Andrew Masterson regarding memorandum in support of motion[16]

Exhibit 1

SEALED EXHIBIT by Plaintiff Paddington & Company Ltd. Exhibit 2, Parts 1-7 regarding declaration[17]

MOTION by Plaintiff Paddington & Company Ltd. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief[19]

Declaration of Martin F. Trainor

Exhibit 1

MOTION by Plaintiff Paddington & Company Ltd. to Withdraw as Counsel

MINUTE entry before the Honorable Jeffrey I Cummings: Attorney's motion to withdraw [21] is granted. Elizabeth J. Banegas is terminated as counsel. Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: This case has been assigned to the calendar of Judge Jeffrey I. Cummings. The Court notes that plaintiff has presented evidence of completed purchases of the allegedly infringing products to customers in Illinois, (Dckt. #18). See Liu v. Monthly, No. 25-2074, --- F.4th ----, 2026 WL 880018 (7th Cir. Mar. 31, 2026). Accordingly, plaintiff's motion for leave to file under seal [3], motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [15], and motion for electronic service of process [19] are granted as to Amended Schedule A. 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. 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. Status hearing is set for 5/1/26 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeffrey I Cummings on 4/2/2026

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Amended Complaint by Plaintiff Paddington & Company Ltd.

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

SURETY BOND in the amount of $ 10,000.00 posted by Paddington & Company Ltd. (Document not scanned)

MOTION by Plaintiff Paddington & Company Ltd. to Extend the Temporary Restraining Order

MEMORANDUM by Paddington & Company Ltd. in support of motion for miscellaneous relief[28]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the TRO 28 is granted. The TRO entered on 4/2/26 is extended to 4/30/26. The 5/1/26 tracking status hearing is stricken and reset to 5/18/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice.

SUMMONS Returned Executed by Paddington & Company Ltd. as to The Partnerships and Unincorporated Associations Identified On Schedule A on 4/27/2026, answer due 5/18/2026.

Declaration of Martin F. Trainor

Exhibit A

MOTION by Plaintiff Paddington & Company Ltd. for preliminary injunction

Exhibit A

MEMORANDUM by Paddington & Company Ltd. in support of motion for preliminary injunction[32]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction [32]. 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 May 13, 2026." 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 5/18/26 tracking status hearing is stricken and reset to 6/5/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

CERTIFICATE of Service by Martin Francis Trainor on behalf of Paddington & Company Ltd.

Exhibit A

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction [32] 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 6/26/26. The 6/5/26 tracking status hearing is stricken and re-set to 8/21/26 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 5/19/2026: Mailed notice. (bi,)

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NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to certain Defendants

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to a certain defendant

MOTION by Plaintiff Paddington & Company Ltd. for extension of time

Exhibit A

MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for extension of time to file a motion for order default and default judgment 40 is granted. Plaintiff shall file its motion on or before 7/28/26. Mailed notice

NOTICE of Voluntary Dismissal by Paddington & Company Ltd. as to certain Defendants

MOTION by Plaintiff Paddington & Company Ltd. for entry of default, MOTION by Plaintiff Paddington & Company Ltd. for default judgment as to all Defendants

(Exhibit)

MEMORANDUM by Paddington & Company Ltd. in support of motion for entry of default, motion for default judgment 43

(Exhibit)

DECLARATION of Martin F. Trainor regarding memorandum in support of motion 44

(Exhibit)

ATTORNEY Appearance for Plaintiff Paddington & Company Ltd. by Victor Benjamin Chahin, Jr

DECLARATION of Victor B. Chahin regarding memorandum in support of motion 44

MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion [43] 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 9/4/26. 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 8/21/26 tracking status hearing is stricken and reset to 9/28/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

CERTIFICATE of Service by Victor Benjamin Chahin, Jr on behalf of Paddington & Company Ltd.

Exhibit A