2022-cv-03413

COMPLAINT filed by The Gillette Company LLC; Filing fee $ 402, receipt number AILNDC-19609426.

Exhibit 1 - U.S. Trademark Registration Certificates

Exhibit 2 - January 2011 Mark Monitor Report

Exhibit 3 - 2012 Mark Monitor article

Exhibit 4 - 2020 IPR Seizures Statistics Report

Exhibit 5 - 2017 IPR Seizure Statistic Report

Exhibit 6 - Frontier Economics report

Exhibit 7 - Sept. 2020 U.S. Customs_ Protection Release

Exhibit 8 - Daniel C.K. Chow article

Exhibit 9 - January 2020 Homeland Security Report

Exhibit 10 - Federal Research Division of the Library of Congress report

(Exhibit 11 - 2021 Review of Notorious Markets)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Scott E. Rogers

SEALED EXHIBIT by Plaintiff The Gillette Company LLC Schedule "A" to Plaintiff's Complaint

MOTION by Plaintiff The Gillette Company LLC for temporary restraining order, including a temporary injunction, a temporary transfer of the Defendants' Domain Names, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication

MEMORANDUM by The Gillette Company LLC in support of motion for temporary restraining order, 5

DECLARATION regarding memorandum in support of motion 6 PAUL BRANDSTETTER

Exhibit 1 - U.S. Trademark Registration Certificates

Exhibit 2 - Screenshot Printouts of Internet Stores [REDACTED]

Exhibit 3 - 2012 Mark Monitor article

Exhibit 4 - CBP Reports FY 2020 and Media Release

Exhibit 5 - Frontier Economics report

Exhibit 6 - Daniel C.K. Chow article

Exhibit 7 - January 2020 Homeland Security Report

Exhibit 8 - February 2020 USPTO Report

(Exhibit 9 - 2021 Review of Notorious Markets)

DECLARATION regarding memorandum in support of motion 6 IAN MCDANIEL

Exhibit 1 - Screenshot Printouts of Internet Stores [REDACTED]

(Exhibit 2 - Brand Solutions International Investigation Reports [REDACTED])

SEALED EXHIBIT by Plaintiff The Gillette Company LLC Exhibit 2 to the Declaration of Paul Brandstetter [UNREDACTED] regarding declaration, 7

SEALED EXHIBIT by Plaintiff The Gillette Company LLC Declaration of Ian McDaniel [UNREDACTED] with Exhibit 1 and Exhibit 2 [UNREDACTED] regarding declaration, 8

MOTION by Plaintiff The Gillette Company LLC for leave to file under seal

MOTION by Plaintiff The Gillette Company LLC for leave to file excess pages

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Gillette Company LLC

NOTICE of Claims Involving Trademarks pursuant to Local Rule 3.4 by The Gillette Company LLC

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment.

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.

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Brett James Geschke

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motions for leave to file under seal 11 and for leave to file excess pages 12 are granted. The plaintiff is directed to submit a proposed temporary restraining order, in Word format, to the Court's proposed order inbox (Proposed_Order_Tharp@ilnd.uscourts.gov). Mailed notice

ATTORNEY Appearance for Plaintiff The Gillette Company LLC by Jocelyn C Smith

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 5 is granted. Enter temporary restraining order. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, Unincorporated Associations and Others Identified in Schedule A Hereto

CIVIL BOND for Temporary Restraining Order in the amount of $ 22,000 posted by The Gillette Company LLC. (Document not Imaged).

MOTION by Plaintiff The Gillette Company LLC for extension of time PLAINTIFF'S MOTION TO EXTEND THE TEMPORARY RESTRAINING ORDER

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order 21 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 8/1/2022. Mailed notice

MOTION by Plaintiff The Gillette Company LLC for preliminary injunction

MEMORANDUM by The Gillette Company LLC in support of motion for preliminary injunction 24

(DECLARATION of Scott E. Rogers)

DECLARATION of Brett J. Geschke

AFFIDAVIT of Service filed by Plaintiff The Gillette Company LLC Summons, Complaint, TRO, et al. served on G. Nakamura on August 4, 2022

DECLARATION of Brett J. Geschke on electronic service upon all Defendants

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, the plaintiff's motion for entry of a preliminary injunction [24] is granted in part. The Schedule A attached to the order excludes those defendants who the plaintiff indicates have not been served notice in accordance with Fed. R. Civ. Pro 65. Enter preliminary injunction order. Mailed notice

PRELIMINARY Injunction Order. Signed by the Honorable John J. Tharp, Jr on 8/16/2022. Mailed notice

ATTORNEY Appearance for Defendant iuoe825 by Theodore Joseph Chiacchio

MOTION by Defendant iuoe825 for extension of time to file answer

MOTION by Plaintiff The Gillette Company LLC to Extend Preliminary Injunction Order

(Exhibit A - Amended Schedule A to Preliminary Injunction)

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant iuoe825's unopposed, motion for an extension of time to answer or otherwise plead 32 is granted. The defendant's responsive pleading is due by 09/07/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:All defendants having now been served, the plaintiff's motion to extend preliminary injunction order 33 is granted. Enter order. Mailed notice

ORDER Extending the Preliminary Injunction Order To All Defendants Signed by the Honorable John J. Tharp, Jr on 8/18/2022. Mailed notice

MOTION by Defendant iuoe825 for extension of time to file answer

MINUTE entry before the Honorable John J. Tharp, Jr:Defendant iuoe825's unopposed motion to extend time to respond to complaint 37 is granted. The defendant's responsive pleading is due by 09/21/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The Court is in receipt of the plaintiff's and Defendant caycock05's stipulated consent judgment. The parties are directed to resubmit the stipulated consent judgment, in Word format, to the Court's proposed order inbox (Proposed_Order_Tharp@ilnd.uscourts.gov). Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant caycock05. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 9/29/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendants Nos. 3, 6, 10, 13, 14, and 15. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/4/2022. Mailed notice

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Tonya Lynn D.B.A. 1clothingdeals4u

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Arlene Rodriguez D.B.A. arodrichi4843

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Burak Pulatkan D.B.A. Ege Store

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Esengul Dasdemir D.B.A. ESL LLC

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Halil Ibrahim Onay D.B.A. halil store ibrahim

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Merve Gokmese D.B.A. RAV Trading

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Tayfun Baris Zengin D.B.A. TBZSHOP USA

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Andrew Surmiak D.B.A. thingtrader

DECLARATION of Brett J. Geschke

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant Zeynep Golbasi D.B.A. z Deals LLC

DECLARATION of Brett J. Geschke

ATTORNEY Appearance for Defendant Andrew Surniak d/b/a thingtrader by Erin Kathryn Russell

ANSWER to Complaint by Andrew Surniak d/b/a thingtrader

MINUTE entry before the Honorable John J. Tharp, Jr: Defendant thingtrader having answered, the plaintiff's application for entry of default for Defendant thingtrader 51 is denied. The plaintiff's applications for entry of default for Defendants. No. 1, 2, 7, 8, 12, 18, 20, and 22 44 45 46 47 48 49 50 52 are granted. The Clerk is directed to enter the defaults of Defendants No. 1, 2, 7, 8, 12, 18, 20, and 22 pursuant to Fed. R. Civ. Pro. 55(a). The plaintiff is directed to consolidate any future applications for entry of default for multiple defendants into one application. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant avenueofdeals. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/13/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant mjp472. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/17/2022. Mailed notice

MOTION by Plaintiff The Gillette Company LLC for default judgment as to certain Defendants

MEMORANDUM by The Gillette Company LLC in support of motion for default judgment[60]

Exhibit 1 - Declaration of Brett J. Geschke

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default judgment 60 is taken under advisement. Any objections or responses are due by 10/28/2022.Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendants thingtrader and sellonlynew. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/24/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant evenezer-7. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/26/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant arodrichi4843. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 11/1/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for entry of default judgment 60 is granted. Enter default judgment order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 11/1/2022. Mailed notice

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice.

MINUTE entry before the Honorable John J. Tharp, Jr: Plaintiff's request--received by the Court via e-mail--to approve the stipulated consent judgment is granted. Enter consent judgment. The civil case is terminated as to defendant graphiteblkx5. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 1/3/2023. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff is directed to file a status report by 02/17/2023 regarding any active defendants remaining in this case. Mailed notice

STATUS Report in Response to the February 10, 2023 Order [Dkt. #74] by The Gillette Company LLC

MOTION by Plaintiff The Gillette Company LLC for entry of default of Burak Bedir D.B.A. PointVise

Declaration of Brett J. Geschke

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's application for entry of default [76] is granted. Pursuant to Fed. R. Civ. P. 55(a), the Clerk is directed to enter the default of defendant No. 17. Mailed notice

MOTION by Plaintiff The Gillette Company LLC for default judgment as to Defendant Burak Bedir D.B.A. PointVise

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for default judgment against defendant No. 17 [78] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 3/31/2023. Mailed notice