2025-cv-21463

COMPLAINT against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18323103, filed by The Liverpool Football Club And Athletic Grounds Limited.

(Civil Cover Sheet)

Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

(Complaint) (cwc)

Plaintiff's Corporate Disclosure Statement by The Liverpool Football Club And Athletic Grounds Limited identifying Corporate Parent N.E.S.V. I, LLC for The Liverpool Football Club And Athletic Grounds Limited

MOTION For Leave To File Under Seal by The Liverpool Football Club And Athletic Grounds Limited.

(Text of Proposed Order)

Clerk's Notice to Filer re 5 Motion For Leave To File Under Seal. Wrong Event Selected; ERROR - The Filer selected the wrong event; Motion to Seal event was not selected. The document was corrected by the Clerk. It is not necessary to refile this document.

PAPERLESS ORDER granting 5 Plaintiff's Motion to File Under Seal. Plaintiff may file Schedule A to its Complaint and the Summonses under seal. Schedule A and the Summonses shall remain under seal until the Court has the opportunity to rule on Plaintiff's forthcoming request for ex parte injunctive relief. Signed by Judge Darrin P. Gayles on 4/1/2025. (hs01)

Sealed Document Schedule A to Complaint re DE# 7 Order on Motion to Seal, by The Liverpool Football Club And Athletic Grounds Limited.

Plaintiff's EX PARTE MOTION Ex Parte Motion for Entry of Temporary Restraining Order and Preliminary Injunction, Including a Temporary Injunction, Temporary Asset Restraint and Expedited Discovery by The Liverpool Football Club And Athletic Grounds Limited.

Declaration of David Wokoun, Esq.

Declaration of Paul Dicken

Exhibit 1 to Declaration of Paul Dicken

Exhibit 2 to Declaration of Paul Dicken

(Text of Proposed Order) Added MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction on 4/9/2025 (scn)

EX PARTE MOTION Ex Parte Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) by The Liverpool Football Club And Athletic Grounds Limited.

Declaration of David Wokoun, Esq.

(Text of Proposed Order)

PAPERLESS ORDER TO SHOW CAUSE. In the Complaint, Plaintiff alleges that the 74 Individuals, Partnerships, and Unincorporated Associations Identified on Schedule "A" (Defendants) have engaged in trademark infringement in this district "either individually or jointly" by "operat[ing] one or more e-commerce stores under the Seller Aliases listed in Schedule A." [ECF No. 1]. Federal Rule of Civil Procedure 20(a) permits joinder of defendants in the same action where the plaintiff's claims against the defendants arise "out of the same transaction, occurrence, or series of transactions or occurrences," and "any question of law or fact common to all defendants will arise in the action." Fed. R. Civ. P. 20(a)(2)(A)(B). The Eleventh Circuit has defined "transaction or occurrence" as "all logically related events entitling a person to institute a legal action against another." Alexander v. Fulton Cnty., Ga., 207 F.3d 1303, 1323 (11th Cir. 2000), overruled on other grounds by Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003). In intellectual property cases, a plaintiff cannot satisfy Rule 20's requirements by alleging that multiple defendants have infringed the same patent or trademark. Omega, SA v. Individuals, Bus. Entities, & Unincorporated Associations Identified on Schedule "A", 650 F. Supp. 3d 1349, 1352 (S.D. Fla. 2023). Accordingly, on or before April 21, 2025, Plaintiff shall file a memorandum showing why joinder of the 74 Defendants is proper. Signed by Judge Darrin P. Gayles on 4/7/2025. (hs01)

RESPONSE TO ORDER TO SHOW CAUSE re 11 Order to Show Cause, by The Liverpool Football Club And Athletic Grounds Limited.

AMENDED COMPLAINT against All Defendants, filed by The Liverpool Football Club And Athletic Grounds Limited.

Sealed Document Amended Schedule A to Amended Complaint re DE# 7 Order on Motion to Seal, by The Liverpool Football Club And Athletic Grounds Limited.

ORDER ON PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION, INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, AND EXPEDITED DISCOVERY: Ex Parte Motion for Entry of Temporary Restraining Order is granted. Preliminary Injunction Hearing set for 4/23/2025 11:30 AM in Miami Division before Judge Darrin P. Gayles. Signed by Judge Darrin P. Gayles on 4/10/2025.

ORDER AUTHORIZING ELECTRONIC SERVICE OF PROCESS ON DEFENDANT PURSUANT TO FED. R. CIV. P. 4(f)(3): Granting 10 Ex Parte Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3). The Clerk of Court is directed to CLOSE this case for administrative purposes pending service on Defendant. Signed by Judge Darrin P. Gayles on 4/10/2025.

Civil Case Terminated per DE#16. Closing Case.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

Stricken per DE 21 - NOTICE of Bond Filing and Compliance with Order by The Liverpool Football Club And Athletic Grounds Limited.

(Bond) Modified text on 4/16/2025 (drz)

Clerk's Notice to Filer re 18 Notice (Other). Conventional Filing Filed Electronically; CORRECTIVE ACTION REQUIRED WITHIN 3 DAYS - The Filer failed to submit the document in the conventional paper format. The Filer must file a Notice of Striking, then refile the document in the conventional paper format.

Surety BOND in the amount of $10,000.00 posted by The Liverpool Football Club And Athletic Grounds Limited Approved by Judge Darrin P. Gayles.

NOTICE of Striking 18 Notice (Other) filed by The Liverpool Football Club And Athletic Grounds Limited by The Liverpool Football Club And Athletic Grounds Limited

EX PARTE MOTION to Extend Temporary Restraining Order and Reschedule Hearing on Motion for Preliminary Injunction by The Liverpool Football Club And Athletic Grounds Limited.

Declaration of David Wokoun, Esq.

(Text of Proposed Order)

ORDER granting 22 Motion to Extend Ex Parte Temporary Restraining Order and Reschedule Hearing on Motion for Preliminary Injunction. Motion Hearing for Preliminary Injunction set for 5/7/2025 01:00 PM in Miami Division before Judge Darrin P. Gayles. Signed by Judge Darrin P. Gayles on 4/21/2025. See attached document for full details.

MOTION to Reschedule May 7th Hearing on Motion for Preliminary Injunction by The Liverpool Football Club And Athletic Grounds Limited.

PAPERLESS ORDER granting 24 Plaintiff's Motion to Reschedule May 7th Hearing on Motion for Preliminary Injunction. The Preliminary Injunction hearing is reset for May 7, 2025, at 11:00 a.m. Plaintiff shall provide Defendants with notice of the hearing date and time. **TIME CHANGE ONLY** Signed by Judge Darrin P. Gayles on 4/22/2025. (hs01)

NOTICE of Filing Proposed Summons(es) by The Liverpool Football Club And Athletic Grounds Limited

(Summon(s))

Summons Issued as to The Partnerships And Unincorporated Associations Identified On Schedule A.

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Nanchang Choosen Import & Export Co., Ltd.

(Exhibit 1)

MOTION to Unseal Case by The Liverpool Football Club And Athletic Grounds Limited. Responses due by 5/15/2025.

(Text of Proposed Order)

SERVICE (Proof) by Publication by The Liverpool Football Club And Athletic Grounds Limited. Last Publication date 4/30/2025. Claims/Positions/Written Defenses/Answers/etc., due by 5/30/2025.

Declaration of David Wokoun, Esq.

(Exhibit A to Declaration of David Wokoun, Esq.)

PAPERLESS ORDER granting 29 Plaintiff's Motion to Unseal. The Clerk of Court is directed to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Darrin P. Gayles on 5/6/2025. (hs01)

PAPERLESS Minute Entry for proceedings held before Judge Darrin P. Gayles: Hearing held on May 7, 2025, on Plaintiff's Motion for Preliminary Injunction. Attorney Appearance: David B. Rosemberg. Court Reporter: Gilda Pastor-Hernandez, 305-523-5118 / Gilda_Pastor-Hernandez@flsd.uscourts.gov. (hs01)

ORDER granting 9 Motion for Preliminary Injunction. Signed by Judge Darrin P. Gayles on 5/7/2025. See attached document for full details. (hs01)

NOTICE of Voluntary Dismissal of a Certain Defendant by The Liverpool Football Club And Athletic Grounds Limited