2025-cv-01957

COMPLAINT against SCHEDULE A DEFENDANTS (Filing fee, including Administrative fee, $405, receipt number APAWDC-9253660), filed by PUSHPEEL LLC.

Exhibit 1 - US Patent No. 12,478,892

Exhibit 2 - Combating Trafficking in Counterfeit and Pirated Goods

Exhibit 3 - Intellectual Property Rights Seizure Statistics

Exhibit 4 - Claim Charts

Civil Cover Sheet

Temporary Restraining Order

Miscellaneous Relief (Use ONLY if no other relief applies)

Sealed Order

ORDER GRANTING [3] MOTION for Leave to File Documents Under Seal. DO NOT electronically file the sealed version of the document until you electronically file the redacted version of the document, using the Redacted Document event, unless otherwise ordered by the Court. You are required to serve the sealed document on counsel using traditional service methods. Decision to Unseal Document deferred. Signed by Judge Mark R. Hornak on 12/23/25.

Order

Order (Text entry; no document attached.)

SEALED MOTION This document Sealed pursuant to [7] Order on Motion for Leave to File Documents Under Seal, by PUSHPEEL LLC. (Attachments: # (1) Proposed Order TRO, # (2) Declaration Murphy, # (3) Declaration Ference, # (4) 1 Intellectual Property Rights Seizure Staticitics, # (5) 2 Northwestern Journal of International Lay & Business, # (6) 3 Combatting Trafficking in Counterfeit & Pirated Goods, # (7) Declaration Odell, # (8) 1 Composite, # (9) 2 Composite, # (10) 3 Composite, # (11) 4 Composite, # (12) 5 Composite, # (13) 6 Compsoite, # (14) 7 Compsoite, # (15) 8 Composite, # (16) 9 Composite, # (17) 10 Composite, # (18) 11 Composite, # (19) 12 Compsoite, # (20) 13 Composite, # (21) 14 Composite, # (22) 15 Composite)

SEALED MOTION This document Sealed pursuant to [7] Order on Motion for Leave to File Documents Under Seal, by PUSHPEEL LLC. (Attachments: # (1) Proposed Order Exceed Page Limit)

SEALED MOTION This document Sealed pursuant to [7] Order on Motion for Leave to File Documents Under Seal, by PUSHPEEL LLC. (Attachments: # (1) Proposed Order Alternative Service, # (2) Exhibit, # (3) Declaration Ference, # (4) 1 - Hauge Conference on Private International Law)

ORDER DIRECTING THE FILING OF AMENDED/SUPPLEMENTAL PAPERS BY PLAINTIFF. The Plaintiff has filed this action alleging the infringement of one or more United States Patents. The papers of record indicate that the Plaintiff asserts that there are 237 Defendants in the action. The Plaintiff has proffered what appear to be exemplars of alleged infringing products, with the depictions of such products buried (in the court's estimation) in advertisements/on-line postings/depictions of numerous products of each Defendant. None of the exemplars are organized or arranged by "Defendant number" corresponding to the Schedule A listing advanced by the Plaintiff, nor do they appear to be presented in any readily-apparent organized fashion, as opposed to what is essentially a blob of photographs of such allegedly infringing products, coupled with the US Patent asserted in the action with its included diagrams. And as noted above, there are 200+ such Defendants/allegedly infringing products. The Plaintiff seeks extraordinary relief. For the Court to consider the same, it is obligated to perform an item-by-item examination to assess, among other things, likelihood of success on the merits of the Plaintiff's claims. That it cannot do with precision nor any version of reasonable efficiency given the nature of the Plaintiffs filings. Plaintiff needs a "do over". The Court will take no action based on the papers of record. Should the Plaintiff seek such action/relief, Plaintiff must file such amended documents that will permit the Court to readily identify which exemplars relate as to each scheduled Defendant, and in a readily organized fashion, e.g. listing numerical order/alphabetical order, or the like, with the exemplars of the patented product and the allegedly infringing product side by side, or the equivalent. Signed by Judge Mark R. Hornak on 3/13/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Order (Text entry; no document attached.)

SEALED ORDER re [11] SEALED MOTION. This document Sealed pursuant to [7] Order on Motion for Leave to File Documents Under Seal, filed by PUSHPEEL LLC. Signed by Judge Mark R. Hornak on 4/6/26.

ORDER re [12] Sealed Motion. Signed by Judge Mark R. Hornak on 4/6/26.

ORDER re [13] Sealed Motion. Signed by Judge Mark R. Hornak on 4/6/26.