2026-cv-01953

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-24755434.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Exhibit 3 to the Complaint

Exhibit 4 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

(Exhibit 4 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 Katherine M. Kuhn

Exhibit 2 to the Declaration of Katherine M. Kuhn

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Declaration of Katherine M. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [4]

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

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.

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 3).

MAILED copyright report to Registrar, Washington DC. (qrtr,)

First AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against Swim Chic Elite and terminating The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A

Exhibit 1 to the First Amended Complaint

Exhibit 2 to the First Amended Complaint

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the First Amended Complaint regarding amended complaint, [11]

MINUTE entry before the Honorable Franklin U. Valderrama: On or before 5/14/2026, the parties shall file a joint initial status report. A template for the Joint Initial Status Report, setting forth the information required, may be found at http://www.ilnd.uscourts.gov/Judges.aspx by clicking on Judge Valderrama's name and then again on the link entitled 'Joint Initial Status Report. Plaintiff must serve this Minute Entry on all other parties. If the defendant(s) has not been served with process by that date, plaintiff's counsel is instructed to file an individual status report indicating the status of service of process by the same deadline. The parties are further ordered to review all of Judge Valderrama's standing orders and the information available on his webpage. Any nongovernmental corporate party that qualifies under the Rules is reminded of the requirement to file a disclosure statement under Federal Rule of Civil Procedure 7.1/N.D. Ill. Local Rule 3.2. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's motion for leave to file under seal [4]. The Court, like many other courts in this District, is unconvinced that "these commonplace efforts in Schedule A cases to obtain secret relief comport with principles of procedural due process." See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 2025 WL 2299593 at *7 (N.D. Ill. Aug. 8, 2025) (Kness, J.); see also Shenzhen Jisu Technology Co. LTD. v. The Partnerships and Unincorporated Associations Identified in Schedule A, 25-cv-09559 Dkt. No. 10 (N.D. Ill. Aug. 19, 2025) (Hunt, J.). As an initial matter, these infringement cases rarely present exceptional circumstances that would justify sealing the names of all defendants and documents pertaining to their alleged infringing activity, let alone an entire case, even temporarily. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." Eicher Motors, 2025 WL 2299593 at *7. And, importantly, the reasoning underlying Plaintiff's motion to seal runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000). It is insufficient that alleged counterfeiters might quickly shut down the online store and move money if alerted to the fact that they are being sued. See Shenzhen Jisu Technology Co., 25-cv-09559 Dkt. No. 10. "Due process still affords them the right to receive notice and a chance to present a defense before restraining all of their assets based solely on one-sided documentary evidence from Plaintiff." Id. Therefore, without a detailed explanation to establish good cause for sealing in accordance with Local Rule 26.2 and Seventh Circuit precedent, which has not been provided here, sealing is not appropriate. Accordingly, Plaintiff's motion to seal [4] is denied, and the Clerk of Court is directed to unseal the entire case, forthwith. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

Memorandum in Support of Plaintiff's Motion for Temporary Restraining Orde

Declaration of K. Kuhn in Support of Plaintiff's Motion for Temporary Restr

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Declaration of A. Beaston in Support of Plaintiff's Motion for Temporary Re

Declaration of L. Li in Support of Plaintiff's Motion for Temporary Restrai

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's ex parte motion for a TRO [15] is denied without prejudice. Plaintiff has not come close to meeting the exacting standards of Fed. R. Civ. P. 65(b) to warrant ex parte relief. That is, the Court finds that "the generic copy-and-paste declarations made mostly 'upon information and belief' fall well short of providing 'specific facts' to 'clearly show that immediate and irreparable injury, loss or damage will result,' and also fail to satisfy the certification requirement." Ren et al v. AilunUS, 25-cv-09278 Dkt. 32 (N.D. Ill. Aug. 22, 2025). That is ample reason to deny this extraordinary request. See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A., No. 25 C 2937, 2025 WL 2299593 at *4-7 (N.D. Ill. Aug. 8, 2025) (Kness, J.) ("Given that any irreparable harm wrought by infringement can, as with more traditional forms of IP litigation, be addressed through preliminary injunctive relief following an adversarial proceeding, the use of Rule 65(b) to ensure an unimpeded path to a prejudgment asset restraint is unsound."). The Court acknowledges that, in earlier Schedule A cases, granted similar TRO motions. See, e.g., Milwaukee Electric Tool Corporation v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, 25-cv-08835 Dkt. 22 (Aug. 19, 2025). However, upon further consideration of the issue, including a review of Judge Kness's thorough order in Eicher Motors, the Court finds that the present TRO request does not satisfy Rule 65(b)'s requirements. Plaintiff may be allowed to seek discovery to assist with identifying defendant, but any such request must be presented in a separate motion. Mailed notice.

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

Memorandum in support of Motion for Expedited Discovery

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

MINUTE entry before the Honorable Franklin U. Valderrama: The Court denies Plaintiff's motion for expedited discovery [17]. Under the Court's discretion, it finds the information sought is more appropriately addressed in the regular course of discovery. 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