2026-cv-02769

COMPLAINT filed by Bigfoot 4x4, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-24837463.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by John Wilson

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Elizabeth Aubree Miller

MOTION by Plaintiff Bigfoot 4x4, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bigfoot 4x4, Inc.

Notice of Claims Involving Trademarks by Bigfoot 4x4, Inc.

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Young B. Kim. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff Bigfoot 4x4, Inc. to unseal document Plaintiff's Motion to Unseal Docket No. 9

NOTICE of Motion by Michael A. Hierl for presentment of motion to unseal document 14 before Honorable LaShonda A. Hunt on 3/24/2026 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. Upon review of the trademark infringement complaint and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all 66 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule A,No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 66 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. The Court also questions whether Plaintiff has shown that it can exercise personal jurisdiction over the defendants. To establish personal jurisdiction, Plaintiff must sufficiently allege that the defendants actually sold the allegedly infringing product to a customer in Illinois. See Liu v. Monthly, et al., No. 25-2074, Dkt. 35 (7th Cir. Mar. 9, 2026) (unpublished) (citing Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 400 (7th Cir. 2020)). Although Liu is a nonprecedential disposition, the Court agrees with the reasoning and conclusion regarding the issue of allegations sufficient to support specific personal jurisdiction. Accordingly, by 3/26/26, Plaintiff must file either a memorandum explaining why joinder and personal jurisdiction are proper or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity and grounds for personal jurisdiction. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Finally, the Court construes Plaintiff's motion to unseal 14 as a motion to withdraw its motion for leave to seal 8 and grants the motion. The Clerk is directed, forthwith, to unseal the document at 9. Plaintiff's motion to seal 8 is withdrawn. The motion hearing set for 3/24/26 15 is stricken. Mailed notice (gel,)

MOTION by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff Bigfoot 4x4, Inc. to expedite Plaintiff's Motion for Expedited Discovery

NOTICE of Motion by Michael A. Hierl for presentment of motion for miscellaneous relief 17, motion to expedite 18 before Honorable LaShonda A. Hunt on 3/24/2026 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motions for electronic service of process 17 and for expedited discovery 18 are denied. Plaintiff is directed to review and comply with the Court's March 19, 2026 Order 16 entered prior to the filing of these motions before seeking other relief. Mailed notice (gel,)

AMENDED complaint by Bigfoot 4x4, Inc. against the Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

(Amended Schedule A)

DECLARATION of Ann C. Trent

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable LaShonda A. Hunt: In compliance with the Court's prior Order 16, Plaintiff has filed an amended complaint naming one defendant 21 and has submitted proof that the Defendant sold the allegedly infringing product to a customer in Illinois [22-2]. The Court is now satisfied that personal jurisdiction has been established with respect to that Defendant. The Clerk is directed, forthwith, to update the case caption and case title on the docket to reflect that Defendant is "Ci-Essentials." Plaintiff has also filed a declaration 22, which, confusingly, lacks a case number in the caption, refers to "Defendants" throughout, and asserts that Plaintiff requires a temporary restraining order, yet Plaintiff has not moved for such relief. Counsel is reminded to carefully proofread documents before filing them on the docket. If no other appropriate relief has been sought, Plaintiff is ordered to file a status report by 4/16/26 with proposed next steps in the case. Mailed notice.

MOTION by Plaintiff Bigfoot 4x4, Inc. to reassign case Plaintiff's Motion to Reassign Case No. 26-cv-3882

NOTICE of Motion by Michael A. Hierl for presentment of motion to reassign case 24 before Honorable LaShonda A. Hunt on 4/16/2026 at 10:00 AM.

MOTION by Plaintiff Bigfoot 4x4, Inc. to reassign case Plainttif's Motion to Reassign Case No. 26-cv-3881

NOTICE of Motion by Michael A. Hierl for presentment of motion to reassign case 26 before Honorable LaShonda A. Hunt on 4/16/2026 at 10:00 AM.

MOTION by Plaintiff Bigfoot 4x4, Inc. to reassign case Plaintiff's Motion to Reassign Case No. 26-cv-3883

NOTICE of Motion by Michael A. Hierl for presentment of motion to reassign case 28 before Honorable LaShonda A. Hunt on 4/16/2026 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: The hearing on Plaintiff's motions for reassignment [24] [26] [28] set for 4/16/26 at 10:00AM in Courtroom 1425 [25] [27] [29] are reset for 10:15AM (TIME CHANGE ONLY). Mailed notice (gel,)

MOTION by Plaintiff Bigfoot 4x4, Inc. Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff Bigfoot 4x4, Inc. to expedite Plaintiff's Motion for Expedited Discovery

NOTICE of Motion by Michael A. Hierl for presentment of motion to expedite 32, motion for miscellaneous relief 31 before Honorable LaShonda A. Hunt on 4/21/2026 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: In-person motion hearing held. For the reasons stated on the record, Plaintiff's motions for reassignment of cases 24, 26 and 28 are denied. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to conduct expedited discovery 32 is granted, but its motion for leave to conduct electronic service 31 is denied as premature. The Court grants Plaintiff's request for expedited discovery as the Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. Plaintiff's request for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) is denied without prejudice. Plaintiff requests "authorization to serve the Defendant on a website and by email to the email address for Defendant identified in Exhibit 2 to the Declaration of Ann C. Trent and any email addresses provided by the third parties," but Exhibit 2 to the Declaration of Ann C. Trent does not identify an email address for Defendant. Thus, Plaintiff has not yet shown that it has a reliable email address at which it may reach Defendant. After completing expedited discovery, any renewed motion must include these details. The motion hearing set for 4/21/26 33 is stricken. If no other appropriate relief has been sought, Plaintiff is ordered to file a status report by 5/8/26 updating the Court on the progress of expedited discovery and proposed next steps in the case. Mailed notice

ORDER AUTHORIZING EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 4/20/2026. Mailed notice