Mattel, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule A

COMPLAINT filed by Mattel, Inc.; Filing fee $ 405, receipt number AILNDC-24835931.

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mattel, Inc. Schedule A regarding complaint[1]

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 regarding complaint[1]

MOTION by Plaintiff Mattel, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Mattel, Inc.

Notice of Claims Involving Trademarks by Mattel, Inc.

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Mattel, Inc. by Hannah Alexa Abes

CASE ASSIGNED to the Honorable Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

MOTION by Plaintiff Mattel, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Mattel, Inc. in support of motion for temporary restraining order[12]

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

Exhibit 1

DECLARATION of Michael Moore regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Mattel, Inc. Exhibit 3 regarding declaration[15]

MOTION by Plaintiff Mattel, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Mattel, Inc. 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 Rebecca R. Pallmeyer: Plaintiff is directed promptly to submit (or identify in the existing record) evidence of sales of infringing products in Illinois. Mailed notice.

SUPPLEMENT to motion for temporary restraining order[12] per [20]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for leave to file under seal [4] is granted. Plaintiff's Ex Parte Motion for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery [12] is granted. Plaintiff's Motion for Electronic Service of Process [17] is granted. Order to enter. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 3/25/2026. Mailed notice.

Registry Deposit Information Form by Mattel, Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Mattel, Inc.

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

SURETY BOND in the amount of $ 50,000.00 posted by Mattel, Inc.

MOTION by Plaintiff Mattel, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by Mattel, Inc. in support of extension of time[27]

DECLARATION of Rachel S. Miller regarding memorandum in support of motion[28]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Ex Parte Motion to extend the Temporary Restraining Order [27] is granted to 4/22/2026. Order to enter. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 4/6/2026. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to a Certain Defendant

MOTION by Plaintiff Mattel, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Mattel, Inc. in support of motion for preliminary injunction[34]

Declaration of Rachel S. Miller

SUMMONS Returned Executed by Mattel, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/17/2026, answer due 5/8/2026.

Declaration of Hannah A. Abes

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of a preliminary injunction [34] is granted. Order to enter. The Clerk of the Court is directed to unseal Schedule A to the Complaint [2], Exhibit 3 to the Complaint [3], Seller Aliases screenshots attached to the Declaration of Michael Moore [16] and the TRO [23]. The Law Firm of Greer, Burns & Crain Ltd. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 4/20/2026. Mailed notice.

NEW PARTIES: 2025 Commerce and Trade, ANHEMUJIN, ANJD, HigzYovn US, INLOLLY, JingChengKai-US, Khuong_HHL, leguo store, luoweihui, Nail Apparel, o-MSL-o, pistro, RAOZHONGM, Ruiniusi, qihe_24123, City Men commercial bank, KING KCZ, SunriseFineGoods, Vibe ss, Xcmpfgx, A happy day, beauty jewelry, Global buyers, huozhuangdianzishangwu's Store, JUNCHOUMAOYI, Lordgothic, mike bill, SUYU, TJCF, TJHK, TJLK, Tongou and xiaokeshangmao's Store added to case caption.

PRO SE Appearance by Defendant Khuong_HHL. (Received via pro se online portal on 5/13/26.)

NOTICE by Khuong_HHL re pro se appearance[39] and report to the court regarding settlement efforts. (Received via pro se online portal on 5/13/26.)

MINUTE entry before the Honorable Rebecca R. Pallmeyer: The Plaintiff is directed to respond to Defendant's report [40] within seven days. Mailed notice.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to a Certain Defendant

RESPONSE by Plaintiff Mattel, Inc. to notice of filing 40 and Motion to Strike 40

MOTION by Plaintiff Mattel, Inc. for entry of default, MOTION by Plaintiff Mattel, Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Mattel, Inc. in support of motion for entry of default, motion for default judgment 44

Exhibit 1

(Exhibit 2)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 45

(Exhibit 1)

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of default and default judgment as to all remaining defendants 44 is granted. Order to enter. The fifty thousand dollar ($50,000) surety bond posted by Plaintiff is hereby released to Plaintiff or its counsel, Greer, Burns, & Crain, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Plaintiff or its counsel. Civil case terminated. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 5/22/2026. Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion to strike [43] is denied, but the court directs that Defendant's response [40] be placed under seal. The court vacates the default judgment as against Defendant Khuong HHL only and refers Plaintiff's claims against Defendant Khong HHL to Magistrate Judge Holleb Hotaling for settlement efforts. Mailed notice.

PURSUANT to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Keri L. Holleb Hotaling for the purpose of holding proceedings related to: settlement conference.Mailed notice.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter has been referred to Judge Holleb Hotaling for a settlement conference between Plaintiff and Defendant Khuong HHL. Therefore, Judge Holleb Hotaling sets an off-the-record pre-settlement conference telephone call for 6/15/2026 at 9:30 a.m. CT (not to exceed 30 minutes). The parties should ensure they call in ONLY at their designated time and not earlier to ensure the pre-settlement call remains private (but not on the record). The counsel that appears for this pre-settlement telephone discussion must be counsel who will represent their respective clients at the conference, or are able to discuss the issues of the case and to schedule the conference on behalf of their clients. The Court expects counsel to discuss issues in the case that may affect the settlement process. Counsel should review Judge Holleb Hotaling's Standing Order on Settlement Conferences prior to the call. The call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

NOTICE of Voluntary Dismissal by Mattel, Inc. as to a Certain Defendant

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Due to the dismissal of Defendant Khuong HHL [Dkt. 52], the pre-settlement call set for 6/15/2026 is hereby stricken. All matters relating to the referral of this case having been resolved, the referral is closed and the case is returned to the assigned district judge. Judge Holleb Hotaling no longer referred to this case.