2026-cv-01824

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-24743609.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Complaint regarding complaint, [1]

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal

Declaration of Katherine M. Kuhn in Support of Motion for Leave to File Under Se

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nazly Aileen Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

MAILED copyright report to Registrar, Washington DC

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 3).

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.

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against Aling's small shop and terminating The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A for Copyright Infringement

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for order for Expedited Discovery

Memorandum in Support of Motion for Expedited Discovery

Declaration of Katherine M. Kuhn in Support of Motion for Expedited Discovery

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for order, [12] before Honorable John Robert Blakey on 3/4/2026 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Plaintiff initiated this lawsuit by filing a single complaint seeking to sue 21 separate defendants for infringement of 13 copyrighted photographs, see [1], [2-1], [2-2]. Once the case was assigned to this Court, Plaintiff filed an amended complaint naming just one defendant and asserting infringement of a single protected photograph, see [11-2]. Before Plaintiff may proceed, however, it must file a supplemental report confirming whether it has previously named any of the 21 defendants identified in this case in a prior case asserting infringement of the same intellectual property. See Julie Stiebritz v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 1:25-cv-03459, at 19 (N.D. Ill. Apr. 9, 2025) (dismissing the case because plaintiff previously named defendants in a prior case and dismissed them to avoid an unfavorable joinder ruling, which constitutes forum shopping). Plaintiff shall file the report by 3/10/26; if Plaintiff fails to comply, the Court will dismiss this case. The Court denies without prejudice Plaintiff's motion for expedited discovery [12], denies as moot Plaintiff's motion to seal [4], and strikes the 3/4/26 Notice of Motion date. The motion remains premised upon Plaintiff's "infringement evidence," but the alleged infringement relates to a photograph of a shirt, not the shirt design, and the submission shows that the infringing photo and the protected photo are not the same. Mailed notice.

SUPPLEMENT to order on motion to seal, order on motion for order, terminate deadlines and hearings, [14] in Compliance with Docket 14

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for order for Expedited Discovery RENEWED

Memorandum in Support of Renewed Motion for Expedited Discovery

Declaration of Katherine M. Kuhn in Support of Renewed Motion for Expedited Disc

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for order, [16] before Honorable John Robert Blakey on 4/1/2026 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the representations in Plaintiff's supplemental report [15], Plaintiff may proceed on its amended complaint [11] against the sole named Defendant, Aling's small shop. The Court grants Plaintiff's renewed motion for an order authorizing expedited discovery [16] and strikes the 4/1/26 Notice of Motion date. Enter Order. Mailed notice.

ORDER Authorizing Expedited Discovery. Signed by the Honorable John Robert Blakey on 3/26/2026. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for protective order Joint Motion for Confidentiality and Protective Order with Third-Party TikTok

Exhibit Confidentiality and Protective Order

Plaintiff's NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion for protective order, [20] before Honorable John Robert Blakey on 4/8/2026 at 11:00 AM.