Revelyst Operations, LLC v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified On Schedule A Hereto

COMPLAINT filed by Revelyst Operations, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-25058657.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Revelyst Operations, LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Revelyst Operations, LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Revelyst Operations, LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Revelyst Operations, LLC by John Wilson

ATTORNEY Appearance for Plaintiff Revelyst Operations, LLC by Elizabeth Aubree Miller

MOTION by Plaintiff Revelyst Operations, LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Revelyst Operations, LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Revelyst Operations, LLC

Notice of Claims Involving Trademarks by Revelyst Operations, LLC

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Laura K. McNally. 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.

EMAILED Trademark report to Patent Trademark Office, Alexandria VA

EMAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Lindsay C. Jenkins for all further proceedings pursuant to IOP 13(f)(1). Mailed notice

(Request for Reassignment)

MINUTE entry before the Honorable Lindsay C. Jenkins: Upon review of the complaint, the Court sua sponte raises the propriety of joining 16 defendants in a single action. By May 13, 2026, plaintiff must file a supplemental memorandum addressing the propriety of joinder. In the alternative, plaintiff has leave to file an amended complaint by May 13, 2026 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting the opinion issued in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025) (Alexakis, J.). Mailed notice.

AMENDED complaint by Revelyst Operations, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Amended Schedule A Hereto

Exhibit 1

(Redline Amended Complaint)

SEALED DOCUMENT by Plaintiff Revelyst Operations, LLC Amended Schedule A

DECLARATION of Paul Mills

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Revelyst Operations, LLC Exhibit 2 to Mills Declaration regarding declaration 18

MEMORANDUM by Revelyst Operations, LLC Plaintiff's Memorandum in Support of Joinder

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED DOCUMENT by Plaintiff Revelyst Operations, LLC Supplemental Chart

MINUTE entry before the Honorable Lindsay C. Jenkins: The court has reviewed Plaintiff's memorandum on joinder 20 and determines that plaintiff has failed to satisfy its burden to show that joinder of more than a dozen defendants is proper in this matter under Fed. R. Civ. P. 20(a)(2). See Este Lauder Cosms. Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, 334 F.R.D. 182, 185 (N.D. Ill. Jan. 27, 2020) (noting that "[plaintiff] bears the burden of demonstrating that joinder is proper"). In evaluating the appropriateness of joinder, the court assesses whether a logical relationship exists between defendants through actual evidentiary overlap, not coincidence. Este Lauder, 334 F.R.D. at 185. Overall, the arguments fall short of establishing a logical relationship among the defendants. The court is not persuaded that the creation of numerous internet stores by individual Defendants that are designed to appear to be selling genuine CQC products satisfies Rule 20. That is, the court cannot see how any one defendant's alleged trademark infringement is linked to the next defendant's infringement sufficient to show they are part of the same transaction, occurrence, or series of transactions or occurrences as required by Rule 20. Plaintiff argues that the Defendants "share unique identifiers, such as design elements and similarities of the counterfeit products offered for sale," which it says suggests Defendants' illegal operations arise out of the same transaction, occurrence, or series of transactions or occurrences. [Dkt. 20 at 4.] Similarities between websites, prices, sales tactics, and unauthorized products do not suggest a logical relationship between defendants. Art Ask Agency v. Individuals, Corps., Ltd. Liab. Cos., P'ships, & Unincorporated Ass'ns Identified on Schedule "A", 2021 WL 5493226, at *2 (N.D. Ill. Nov. 23, 2021). Further a claim that defendants infringed on its trademark in the same way does not sufficiently link one defendant to another. Roadget Bus. Pte. Ltd. v. Individuals, Corps., Ltd. Liab. Companies, P'ships, & Unincorporated Ass'ns Identified on Schedule A Hereto, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) ("Courts in this district generally agree that alleging that multiple defendants have infringed on the same copyright in the same way does not create the substantial evidentiary overlap required to find a similar transaction or occurrence."). Even if the court were mistaken in its joinder analysis, it exercises its discretion to not permit joinder in this case. See Dorsey v. Varga, 55 F.4th 1094, 1103 (7th Cir. 2022). Joining this many defendants in one case simply will not promote judicial economy. See Este Lauder, 334 F.R.D. at 189 ("[P]resenting dozens or hundreds of defendants in one lawsuit actually undermines judicial economy, because this Court must evaluate the evidence submitted in support of liability and, eventually, damages. That is especially true in the ex parte setting of a temporary restraining order, as well as for default-judgment motions."); Art Ask Agency, 2021 WL 5493226, at *3 (noting that "joinder in this case may yield significant financial benefits to [plaintiff] at the judiciary's expense."). Accordingly, the court dismisses Defendant Nos. 2-16 without prejudice. The clerk shall update the case caption to reflect that the Defendant is "DYL5662" Any motion for electronic service of process or request for early discovery should be filed by May 22, 2026. Mailed notice.