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)

MOTION for Temporary Restraining Order by PUSHPEEL LLC.

MOTION TO FILE UNDER SEAL WITH REDACTION REQUIREMENT WAIVER by PUSHPEEL LLC.

Judge Mark R. Hornak added. (Text entry; no document attached.)

(Proposed Order) Modified on 12/17/2025 to select correct relief. (sms)

PATENT/TRADEMARK DOCUMENTS ISSUED.

Docket Sheet

Complaint

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4) (bjr)

SEALED ORDER. Signed by Judge Mark R. Hornak on 12/21/25.

Sealed Docket Entry.

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.

NOTICE that instant civil action has been designated for placement into the United States District Court's Alternative Dispute Resolution program. Parties are directed to fully complete the required 26(f) report, which includes the stipulation of selecting an ADR process. Counsel for plaintiff (or in the case of a removal action, counsel for removing defendant) shall make service of the notice on all parties.

STANDING ORDER AND PROCEDURES ON CIVIL MOTION PRACTICE. Signed by Judge Mark R. Hornak on 1/5/26.

Order (Text entry; no document attached.)

ORDER. The Plaintiff is hereby directed to file any and all proposed Orders as to any relief sought. Signed by Judge Mark R. Hornak on 2/5/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by PUSHPEEL LLC.

Proposed Order TRO

Declaration Murphy

Declaration Ference

1 Intellectual Property Rights Seizure Staticitics

2 Northwestern Journal of International Lay & Business

3 Combatting Trafficking in Counterfeit & Pirated Goods

Declaration Odell

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SEALED MOTION This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal, by PUSHPEEL LLC.

(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.

Proposed Order Alternative Service

Exhibit

Declaration Ference

(1 - Hauge Conference on Private International Law)

SEALED DOCUMENT by PUSHPEEL LLC. This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal.

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PRAECIPE to Issue Summons by PUSHPEEL LLC

(Summons)

Disclosure Statement identifying NONE as corporate parent or other affiliate by PUSHPEEL LLC.

SEALED DOCUMENT by PUSHPEEL LLC. This document Sealed pursuant to 7 Order on Motion for Leave to File Documents Under Seal.

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.)

ORDER DIRECTING PARTIES TO FILE ALL DOCUMENTS ON THE COURT'S DOCKET. The Court hereby notifies all parties to the pending civil action that all statements of position, pleadings, motions, or requests for court action must be filed as such on the official Court docket. Electronic or other message to the Judge or Chambers will not be considered by the Court. The Court directs the parties to the following website in order to register to become an electronic filer: https://pacer.psc.uscourts.gov/pscof/regWizard.jsf. Counsel for the Plaintiff shall transmit a copy of this Order to all Defendants by electronic means, forthwith. Signed by Judge Mark R. Hornak on 3/16/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Remark: EXHIBITS RECEIVED BY CHAMBERS ON THIS DATE.

SEALED DOCUMENT by PUSHPEEL LLC. This document Sealed pursuant to 18 Order.

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.

Surety BOND in the amount of $25,000.00 Receipt Number S-403147, posted by PUSHPEEL LLC NGM Insurance Company as Surety.

ORDER DISMISSING AS MOOT 2 Motion for TRO. Signed by Judge Mark R. Hornak on 4/13/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

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)

SEALED ORDER. Signed by Judge Mark R. Hornak on 4/17/26.

MOTION for attorney Longhao Wang to Appear Pro Hac Vice, (Filing fee $70, Receipt # APAWDC-9514698) by HAPATOYS, RonXn Apostle.

(Affidavit)

ORDER. The following ECF Nos. are hereby UNSEALED on the Court's docket: 5, 6, 11, 12, 13, 14, 17, 21, 22, 23, 24, 27 and 28. Signed by Judge Mark R. Hornak on 4/20/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

ORDER GRANTING 29 Motion for Longhao Wang to Appear Pro Hac Vice. Signed by Judge Mark R. Hornak on 4/20/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

Remark: Email to Chambers from Attorney Wang re the Show Cause Hearing set for this date, 4/20/2026.

ORDER EXTENDING TEMPORARY RESTRAINING ORDER. For the reasons stated on the record at the Show Cause Hearing held on this date, the Court hereby EXTENDS the Temporary Restraining Order currently in place [ECF 22] to and including April 29, 2026, at 12:00 PM EDT. Signed by Judge Mark R. Hornak on 4/20/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.

ORDER CONTINUING SHOW CAUSE HEARING. Upon consultation with counsel for Plaintiff and several Defendants at the scheduled videoconference Show Cause Hearing held this date, the Court hereby CONTINUES the Show Cause Hearing to Friday, April 24, 2026, at 2:00 PM EDT. Videoconference information will be circulated to the Parties. Any party may file any supplemental briefs not later than 12:00 PM EDT on April 23, 2026. Signed by Judge Mark R. Hornak on 4/20/26. Text-only entry; no PDF document will issue. This text-only entry constitutes the Order of the Court or Notice on the matter.