2022-cv-05504

COMPLAINT filed by The Gillette Company LLC; Filing fee $ 402, receipt number AILNDC-19922205.

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 DOCUMENT 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, certified mail, FedEx, and/or electronic publication

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

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Shelia M. Finnegan. Case assignment: Random assignment. (Text entry; no document attached.)

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. (Text entry; no document attached.)

DECLARATION of PAUL BRANDSTETTER regarding memorandum in support of motion 6

Exhibit 1 - U.S. Trademark Registration Certificates

Exhibit 2 - Screenshot Printouts of Internet Stores [REDACTED]

Exhibit 3 - January 2011 Mark Monitor Report

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 of IAN MCDANIEL regarding memorandum in support of motion 6 [REDACTED]

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

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

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

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MINUTE entry before the Honorable Martha M. Pacold: The court has taken Plaintiff's motions under advisement. The court directs Plaintiff to review the court's standing orders for Schedule A cases and follow the instructions there as they apply to these motions and any future motions in this case. (Link: Northern District of Illinois (uscourts.gov))

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for a temporary restraining order 5 is taken under advisement. The proposed temporary restraining order submitted by plaintiff seeks relief broader than the template order on the court's website, without explanation. By 10/28/2022, plaintiff should either resubmit a proposed order that conforms more closely to the template (as well as a track changes version showing any differences from the template) or file a statement of no more than 10 pages explaining why the current proposed order is warranted, including explaining specifically the aspects in which the current proposed order is broader than the template. Plaintiff's motion for leave to file under seal 11 and motion to exceed page limitation 12 are granted.

STATEMENT by The Gillette Company LLC in Support of the Updated Proposed Sealed Temporary Restraining Order

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff has submitted to the proposed order box a revised proposed TRO. However, the track changes version does not show the changes. Plaintiff should resend the track changes version to the proposed order box.

MINUTE entry before the Honorable Martha M. Pacold: For the reasons set forth in plaintiff's motions, the supporting memoranda, and the temporary restraining order, plaintiff's motions for electronic service of process, for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 5 are granted. Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, were defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a substantial likelihood of success on the merits (including evidence of active infringement and sales into Illinois), the harm to plaintiff is irreparable, and an injunction is in the public interest. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendants. As other judges in this district have noted, there may be reason to question both the propriety of the joinder of all defendants in this one action and whether plaintiff genuinely intends to pursue an accounting (which plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the court is persuaded that plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. If any defendant appears and objects, the court will revisit the asset freeze and joinder. Plaintiff shall deposit with the Clerk of Court thirty-two thousand dollars ($32,000.00), either cash or surety bond, as security. Motion for TRO 5 is granted

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Martha M. Pacold on 10/28/2022:

BOND for Temporary Restraining Order in the amount of $ 32,000 posted by The Gillette Company LLC. (document not imaged)

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, Unincorporated Associations and Others Identified in Schedule A Hereto (Text entry; no document attached.)

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 Martha M. Pacold: Plaintiff's ex parte motion to extend the TRO 25 is granted. Under Rule 65(b)(2), the court finds good cause to extend the TRO for 14 days to prevent defendants from transferring assets from their U.S. based financial accounts, modifying the names of their internet stores, or removing their internet stores from their current platforms. The court's TRO 23 entered on 10/28/2022 is extended until 11/25/2022.

AFFIDAVIT of Service filed by Plaintiff The Gillette Company LLC regarding Summons, Complaint, TRO, et al. served on All Defendants on November 9, 2022 and November 18, 2022

MOTION by Plaintiff The Gillette Company LLC for preliminary injunction

MEMORANDUM by The Gillette Company LLC in support of motion for preliminary injunction 28

(DECLARATION of Scott E. Rogers)

DECLARATION of Brett J. Geschke on Defendants' Internet Stores accounts

AFFIDAVIT of Service filed by Plaintiff The Gillette Company LLC regarding Plaintiff's Motion for Preliminary Injunction and supporting Memorandum and Declarations served on All Defendants on November 21, 2022

MOTION by Plaintiff The Gillette Company LLC for extension of time [Plaintiff seeks a SECOND extension of the Temporary Restraining Order]

MINUTE entry before the Honorable Martha M. Pacold: The court has taken the motion for preliminary injunction 28 under advisement and will consider the motion unopposed if no defendant appears and objects by 11/30/2022. Plaintiff shall serve all defendants with this notice.

AFFIDAVIT of Service filed by Plaintiff The Gillette Company LLC regarding this Court's November 22, 2022 Minute Entry [ECF No. 33] served on All Defendants on November 23, 2022

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to extend the Temporary Restraining Order 32 is granted in part. For the reasons stated in the Court's orders entering and extending the TRO, as well as in Plaintiff's earlier motion 26 to extend the TRO, the TRO is further extended to and including the date on which the Court adjudicates the motion for a preliminary injunction 28. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844.

ATTORNEY Appearance for Defendant Hot dealzzz by Mark Berkowitz

MOTION by Defendant Hot dealzzz for extension of time to file response/reply as to motion for preliminary injunction 28 (Unopposed)

MINUTE entry before the Honorable Martha M. Pacold: Defendant Hot Dealzzz's unopposed motion for an extension of time 37 is granted. Defendant Hot Dealzzz's response to Plaintiff's motion for preliminary injunction 28 is due by 12/7/2022.

MINUTE entry before the Honorable Martha M. Pacold: On 11/30/2022, Oulcan Arslan emailed the Emergency Judge on behalf of Defendant No. 22, Pasage_. The court is posting the email and attachments on the docket separately. It is not clear whether Pasage_ is an independent legal entity (such as a corporation, LLC, or other organization formally established under the relevant corporate laws of a country or state) or a d/b/a (i.e. a trade name through which Arslan operates without a formally established business entity). If Pasage_ is an independent legal entity, Pasage_ cannot represent itself, nor can a nonlawyer represent Pasage_, and Pasage_ would need to obtain an attorney and that attorney would need to file an appearance on the docket. Defendant Pasage_'s representative, Arslan, is directed to confer with plaintiff's counsel. Although Pasage_ may not be able to represent itself (depending on whether it is an independent legal entity), the court construes Arslan's email and the attachments as an objection to Plaintiff's motion for preliminary injunction 28 and will consider the preliminary injunction opposed as to defendant Pasage_. Plaintiff's counsel is directed to file a report (after consulting with Arslan) on a joint proposed case schedule with respect to this defendant by 12/15/2022. The court is posting the documents on the docket this once; but going forward, Arslan and defendant Pasage_ are advised that emailing filings to the Emergency Judge or directly to chambers staff is not a proper way of filing documents. Rather, going forward, Arslan and defendant Pasage_ must file filings on the docket of the case, either (1) through the temporary "Email Filing Option for Pro Se Parties" on the court's website at https://www.ilnd.uscourts.gov/Pages.aspx?/2+UWDbtVzCDq3Lu8BusuQ==, or (2) electronically through CM/ECF, or (3) by calling the Clerk's Office to obtain instructions for paper or electronic filing. Further emails, letters, or other documents sent directly to a judge or court staff, or that otherwise fail to comply with these instructions, may be disregarded by the court or returned to Arslan or defendant Pasage_.

email from Ogulcan Arslan (Additional attachment(s) added on 12/1/2022: # 1 Supplement Appeal Letter, # 2 Supplement Customer who buy, # 3 Supplement account statement).

MOTION by Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, Unincorporated Associations and Others Identified in Schedule A Hereto for extension of time to file response/reply as to complaint, 1, motion for preliminary injunction 28

(Affidavit Affidavit of Counsel)

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed the motion filed on behalf of Defendant B. Hive Boutique, LLC. 41, which is a set of two declarations. The court appreciates that counsel who prepared the motion has not been able to find local counsel yet, and thus, cannot move for leave to appear pro hac vice. However, because Attorney Thomas F. Feeney is not a member of the General Bar of this court, the motion 41 is held in abeyance pending the resolution of Defendant B. Hive Boutique's representation, and is subject to being struck without prejudice to renewal if the status of the representation is not resolved by 12/15/2022. See N.D. Ill. L.R. 83.12(a) & 83.14; Husain v. Gold Coast Exotic Imports, LLC et al, No. 22-cv-03564, Dkt. 37 (N.D. Ill. Oct. 27, 2022). Further, the court considers the motion for preliminary injunction 28 opposed as to defendant B Hive Boutique. Plaintiff's counsel is directed to file by 12/15/2022 a report (after consulting with this defendant) on a joint proposed case schedule with respect to this defendant by 12/15/2022.

MOTION by Defendant Hot dealzzz for extension of time to file response/reply as to motion for preliminary injunction 28 (Unopposed)

MINUTE entry before the Honorable Martha M. Pacold: Defendant Hot dealzzz's unopposed motion for extension of time to file response to Plaintiff's motion for preliminary injunction 43 is granted. Defendant Hot dealzzz response to Plaintiff's motion for preliminary injunction 28 is due by 12/21/2022.

RESPONSE by Plaintiff The Gillette Company LLC to December 1, 2022 Order 39 and Proposed Preliminary Injunction Hearing Scheduling and Case Management Order

STATUS Report in Response to the December 2, 2022 Order 42 by The Gillette Company LLC

MINUTE entry before the Honorable Martha M. Pacold: As to plaintiff and defendant Passage_ the court approves the parties' proposed schedule. This case will be referred to the calendar of the Honorable Sheila M. Finnegan to hold proceedings related to discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. The parties are advised that though the court is entering their agreed scheduling order, the referral to Judge Finnegan includes the authority to modify the schedule in any respect.

PRELIMINARY INJUNCTION HEARING SCHEDULING AND CASE MANAGEMENT ORDER Signed by the Honorable Martha M. Pacold on 12/15/2022:

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Sheila M. Finnegan for the purpose of holding proceedings related to: discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. The referral includes the authority to modify the Preliminary Injunction Scheduling and Case Management Order 48 in any respect.

MINUTE entry before the Honorable Sheila M. Finnegan: This case has been referred for discovery supervision and a settlement conference should the parties request one. Magistrate Judge telephone status is set on 2/1/2023 at 9:15 a.m. The toll-free number for the next hearing is 877-336-1831, access code 5995354. Persons granted remote access to proceedings are reminded of the prohibition against recording and rebroadcasting of court proceedings. Mailed notice

MOTION by Defendant Hot dealzzz for extension of time to file response/reply as to motion for preliminary injunction 28 (Unopposed)

MINUTE entry before the Honorable Martha M. Pacold: Defendant Hot dealzzz's unopposed for extension of time 51 to respond to the motion for a preliminary injunction is granted. Defendant Hot dealzzz's response to plaintiff's motion for preliminary injunction 28 is due by 1/16/2023.

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Sheila M. Finnegan: Telephone status hearing on 2/1/2023 is cancelled in light of the parties' reported settlement 53. 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.

STATUS Report [SECOND] in Response to the December 2, 2022 Order 42 by The Gillette Company LLC

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to approve consent judgment 53 is granted. Defendant rkuhn1 is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/10/2023.

STIPULATED CONSENT JUDGMENT Signed by the Honorable Martha M. Pacold on 1/3/2023:

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to approve consent judgment 59 is granted. Defendant elizra-37 is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/16/2023. Enter consent judgment.

STIPULATED CONSENT JUDGMENT Signed by the Honorable Martha M. Pacold on 1/6/2023:

AMENDED Schedule "A" to Plaintiff's Complaint 4

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 63 is granted. Defendant getusom is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/20/2023. Enter consent judgment.

STIPULATED CONSENT JUDGMENT as to defendant getusom. Signed by the Honorable Martha M. Pacold on 1/11/2023:

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to approve consent judgment 66 is granted. Defendants Pixmkr, Hot dealzzz, and sanya5am are dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/20/2023.

STIPULATED CONSENT JUDGMENT as to Pixmkr Signed by the Honorable Martha M. Pacold on 1/13/2023:

STIPULATED CONSENT JUDGMENT as to Hot dealzzz Signed by the Honorable Martha M. Pacold on 1/13/2023:

STIPULATED CONSENT JUDGMENT as to sanya5am Signed by the Honorable Martha M. Pacold on 1/13/2023:

STATUS Report [THIRD] in Response to the December 2, 2022 Order 42 by The Gillette Company LLC

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-20238309.

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed Plaintiff's status report 71 which reflects that Plaintiff and Defendant B Hive Boutique intend to file a stipulated consent judgment by 1/23/2023. The parties are directed to file a further status report by 2/13/2023 if no consent judgment is filed before that date.

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed Attorney Thomas F. Feeney's motion for leave to appear pro hac vice on behalf of Defendant B Hive Boutique, LLC 72. Mr. Feeney is directed to follow the district's online instructions on how to move for leave to appear pro hac vice. https://www.ilnd.uscourts.gov/AppearingPHV.aspx. The court will consider the motion once Mr. Feeney files the correct form. See also Local Rule 83.14.

AMENDED [SECOND] Schedule "A" to Plaintiff's Complaint 4

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 76 is granted. Defendants B Hive Boutique, LLC d/b/a b_hive_boutique a/k/a and Christine G. Carollo are dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/27/2023. Enter Consent Judgment.

STIPULATED CONSENT JUDGMENT as to Defendant b_hive_boutique Signed by the Honorable Martha M. Pacold on 1/24/2023:

MINUTE entry before the Honorable Martha M. Pacold: The court entered an order on 1/18/2023 directing Thomas F. Feeney to follow the district's online instructions on how to move for leave to appear pro hac vice 74. Mr. Feeney has until the end of business on 1/25/2023 to comply with the court's 1/18/2023 order 74 or the original motion for leave to appear pro hac vice 72 may be considered moot.

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 80 is granted. Defendant bo2pooh2002 a/k/a Jose Hernandez is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 1/30/2023.

STIPULATED CONSENT JUDGMENT as to Defendant bo2pooh2002 Signed by the Honorable Martha M. Pacold on 1/25/2023:

MOTION by Plaintiff The Gillette Company LLC for entry of default

(Exhibit 1 - Declaration of Brett J. Geschke)

MINUTE entry before the Honorable Martha M. Pacold: The court takes plaintiff's motion for entry of default 83 under advisement. Any defendant objecting to plaintiff's motion for entry of default and for default judgment 83 must enter an appearance and file a written objection by 2/9/2023. If no objections are filed, the court will consider the motion unopposed. Plaintiff shall serve defendants with this notice.

AFFIDAVIT of Service filed by Plaintiff The Gillette Company LLC regarding this Court's January 27, 2023 Minute Entry Order [ECF No. 84] on January 27, 2023

AMENDED [THIRD] Schedule "A" to Plaintiff's Complaint 4

ORDER: Thomas F. Feeney's application to appear pro hac vice on behalf of defendants B Hive Boutique and Christine Carollo 72 is granted. Signed by the Honorable Martha M. Pacold on 1/31/2023. Mailed notice

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

ATTORNEY Appearance for Defendant bestofluc by Mark Berkowitz

MOTION by Defendant bestofluc for extension of time to file response/reply as to motion for entry of default 83 (Unopposed)

MINUTE entry before the Honorable Martha M. Pacold: Defendant Bestofluc's unopposed motion for an extension of time to respond to Plaintiff's motion for entry of default 91 is granted. Defendant's response to Plaintiff's motion for entry of default 83 is due by 3/2/2023. Plaintiff's reply, if any, is due by 3/16/2023.

ATTORNEY Appearance for Defendant TheGoodBuyz by Stephen M. Komie

MOTION to Defer Responsive Pleading Deadline (MIDP) Unopposed Motion for Leave to File Appearance and to Extend Time, filed by Defendant TheGoodBuyz.

MINUTE entry before the Honorable Martha M. Pacold: Defendant B Hive Boutique's motion for an extension of time to respond to the motion for preliminary injunction 41 is denied as moot in light of B Hive Boutique being dismissed without prejudice 77.

MINUTE entry before the Honorable Martha M. Pacold: Defendant THEGOODBUYZ's unopposed motion for an extension of time answer or otherwise plead to the complaint 94 is granted. THEGOODBUYZ to answer or otherwise plead by 5/9/2023.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motions for entries of stipulated consent judgments 88, 89 are granted. Defendants tztreasures99 and 3julybabies are dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 2/13/2023. Enter consent judgments.

STIPULATED CONSENT JUDGMENT as to defendant tztreasures99 Signed by the Honorable Martha M. Pacold on 2/9/2023:

STIPULATED CONSENT JUDGMENT as to 3julybabies Signed by the Honorable Martha M. Pacold on 2/9/2023:

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 100 is granted. Defendant micdave is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 2/15/2023. Enter consent judgment.

STIPULATED CONSENT JUDGMENT as to defendant micdave Signed by the Honorable Martha M. Pacold on 2/13/2023:

AMENDED [FOURTH] Schedule "A" to Plaintiff's Complaint 4

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 104 is granted. Defendant Deponere is dismissed without prejudice. Plaintiff is directed to file an Amended Schedule A on the docket by 2/21/2023. Enter consent judgment.

STIPULATED CONSENT JUDGMENT as to defendant Deponere Signed by the Honorable Martha M. Pacold on 2/16/2023:

AMENDED [FIFTH] Schedule "A" to Plaintiff's Complaint 4

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 108

AFFIDAVIT of Brett J. Geschke for Service of Plaintiff's Motion for Entry of Default Judgment 108 and Memorandum in Support 109 upon Defaulting Defendants

MOTION by Plaintiff The Gillette Company LLC for entry of default of Defendant No(s). 17, 22, and 27

(Exhibit 1 - Declaration of Brett J. Geschke)

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff is directed to file, by 3/6/2023, a table clearly identifying the status of the case against all defendants, including (1) against which defendants plaintiff is seeking an entry of default and (2) against which defendants plaintiff is seeking default judgment and (3) which defendants are opposing the first motion for entry of default 83.

AFFIDAVIT of Jocelyn C. Smith for Service of Plaintiff's Application for Entry of Default along with Exhibit 1, the Declaration of Brett J. Geschke 111, upon Defendant Nos. 17, 22, and 27

STATUS Report in Response to the February 27, 2023 Order 112 by The Gillette Company LLC

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MOTION by Defendant bestofluc for extension of time to file response/reply as to motion for entry of default 83 (Unopposed)

MINUTE entry before the Honorable Martha M. Pacold: Defendant bestofluc's motion for extension of time to file response to Plaintiff's motion for entry of default 116 is granted. Defendant bestofluc's response to plaintiff's motion for entry of default 83 is due by 3/14/2023. Plaintiff's reply is due by 3/28/2023.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 115 is granted. Defendant bear6829 is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 3/6/2023.

STIPULATED CONSENT JUDGMENT as to bear6829 Signed by the Honorable Martha M. Pacold on 3/2/2023:

MINUTE entry before the Honorable Martha M. Pacold: By 3/16/2023, plaintiff is directed to file a short supplemental brief addressing whether default judgment against some but not all defendants is appropriate under Fed. R. Civ. P. 54(b) and the principles articulated in Frow v. De La Vega, 82 U.S. 552 (1872). See Arwa Chiropractic, P.C. v. Med-Care Diabetic and Medical Supplies, Inc., 961 F.3d 942, 950-52 (7th Cir. 2020); VLM Food Trading Int'l, Inc. v. Illinois Trading Co., 811 F.3d 247, 256 n.6 (7th Cir. 2016); Marshall & Ilsley Trust Co. v. Pate, 819 F.2d 806, 811-12 (7th Cir. 1987); In re Uranium Antitrust Litig., 617 F.2d 1248, 1257-58 (7th Cir. 1980); Krakow Bus. Park v. Locke Lord, LLP, 135 F. Supp. 3d 770, 783 (N.D. Ill. 2015), aff'd sub nom. Domanus v. Locke Lord LLP, 847 F.3d 469 (7th Cir. 2017). Any other party who wishes to file a brief on this point is free to do so by the same deadline. Plaintiff is directed to serve this order on defendants and file a certificate of service on the docket.

AFFIDAVIT of Brett J. Geschke for Service of this Court's March 2, 2023 Minute Entry Order [ECF No. 120]

AMENDED [SIXTH] Schedule "A" to Plaintiff's Complaint 4

SUPPLEMENTAL BRIEF Addressing Whether Default Judgment Against Some But Not All Defendants is Appropriate by The Gillette Company LLC

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed plaintiff's supplemental brief 13. Within the court's discretion to manage its own docket, all three pending motions related to default and default judgment 83, 108, 111 are denied without prejudice to refiling. Plaintiff may refile a single combined motion for default and default judgment once it has reached settlement with the three remaining defendants. 123 at 5. Further, plaintiff is directed to file a status report by 3/23/2023 as to the status of the motion for a preliminary injunction 28 and whether it is currently opposed, if so, by whom it is opposed, and the status of briefing on the motion.

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 125 is granted. Defendant midep_99 is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 3/17/2023.

STIPULATED CONSENT JUDGMENT as to defendant midep_99 Signed by the Honorable Martha M. Pacold on 3/13/2023:

AMENDED [SEVENTH] Schedule "A" to Plaintiff's Complaint 4

STATUS Report in Response to the March 10, 2023 Order 124 by The Gillette Company LLC

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED]

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed Plaintiff's status report 129 and the court will defer consideration of the motion for a preliminary injunction 28 in light of the points raised in the status report. Plaintiff should file an updated status report by 4/18/2023. Plaintiff's motion for entry of stipulated consent judgment 130 is granted. Defendant bestofluc is dismissed without prejudice. Plaintiff is directed to file an amended Schedule A on the docket by 3/24/2023.

STIPULATED CONSENT JUDGMENT as to defendant bestofluc Signed by the Honorable Martha M. Pacold on 3/21/2023:

AMENDED [EIGHTH] Schedule "A" to Plaintiff's Complaint 4

STATUS Report in Response to the March 21, 2023 Order 131 by The Gillette Company LLC

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed plaintiff's status report 134. It reflects that plaintiff and defendant TheGoodBuyz expect to settle by 4/30/2023. Plaintiff is directed to file a further status report by 5/8/2023 if it makes no further filings with respect to defendant TheGoodBuyz before that date.

STATUS Report in Response to the April 14, 2023 Order 135 by The Gillette Company LLC Presented before Presiding Judge

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed plaintiff's status report 136, which reflects that it has reached a settlement in principle with defendant TheGoodBuyz. Plaintiff anticipates filing a stipulated consent judgment by 5/17/2023 and then moving for default and default judgment. Plaintiff is directed to file a status report by 7/10/2023 if no stipulated consent judgment and motion for default and default judgment is filed before that date. Mailed notice

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED] Presented before Presiding Judge

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 138 is granted. Defendant TheGoodBuyz is dismissed without prejudice. Plaintiff is directed to file an Amended Schedule A on the docket by 5/19/2023. Enter consent judgment.

STIPULATED CONSENT JUDGMENT as to defendant TheGoodBuyz Signed by the Honorable Martha M. Pacold on 5/16/2023:

AMENDED [NINTH] Schedule "A" to Plaintiff's Complaint 4

MOTION by Plaintiff The Gillette Company LLC for entry of default and default judgment against remaining Defendants Presented before Presiding Judge

MEMORANDUM by The Gillette Company LLC in support of motion for entry of default 142 and default judgment against remaining Defendants

(Exhibit 1 - Declaration of Brett J. Geschke)

MINUTE entry before the Honorable Martha M. Pacold: The court takes plaintiff's motion for entry of default and default judgment 142 under advisement. Any defendant objecting to plaintiff's motion for entry of default and for default judgment 142 must enter an appearance and file a written objection by 6/7/2023. If no objections are filed, the court will consider the motion unopposed. Plaintiff shall serve defendants with this notice.

AFFIDAVIT of Brett J. Geschke for Service of this Court's May 24, 2023 Minute Entry Order [ECF No. 144]

email from Merinex Yazilim dated 5/25/2023.

(Exhibit) (Main Document 146 replaced on 5/25/2023)

MINUTE entry before the Honorable Martha M. Pacold: The court received an email regarding this case, which the court is posting on the docket 146. Plaintiff must confer with this defendant and file a status report by 6/1/2023.

STATUS Report in Response to the May 25, 2023 Order [Dkt. #147] by The Gillette Company LLC Presented before Presiding Judge

MOTION by Plaintiff The Gillette Company LLC to approve consent judgment [STIPULATED] Presented before Presiding Judge

MINUTE entry before the Honorable Martha M. Pacold: The court has reviewed plaintiff's status report 148. Plaintiff is directed to file a further status report if it does not dismiss defendant LONDON LLC by 6/16/2023.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for entry of stipulated consent judgment 149 is granted. Defendant LONDON LLC Is dismissed without prejudice. Plaintiff is directed to file an Amended Schedule A by 6/7/2023.

STIPULATED CONSENT JUDGMENT as to defendant London LLC a/k/a Merinex Yazilim a/k/a Ferhat Meral Signed by the Honorable Martha M. Pacold on 6/5/2023:

AMENDED [Tenth] Schedule "A" to Plaintiff's Complaint 4

ORDER: In the court's 5/24/2023 minute entry, it gave all defendants until 6/7/2023 to object to plaintiff's motion for entry of default and default judgment 142. See 144. No defendant has objected. The court therefore grants plaintiff's motion for entry of default and default judgment 142. Based on the evidence submitted in support of the temporary restraining order and the motion for entry of default and default judgment, and the admission of liability by virtue of the default, plaintiff has established that the infringement was willful, that damages should be awarded in the amount specified in the order, and that a permanent injunction should be entered. Plaintiff has shown that the infringement of its marks causes it irreparable harm in the form of diminished goodwill and brand confidence, damage to plaintiff's reputation, loss of exclusivity, and loss of future sales; that monetary damages are inadequate to address these harms; and that the public interest would not be disserved by a permanent injunction. No defendants have appeared to argue otherwise; thus, the court also finds that the balance of the hardships favors a permanent injunction. Plaintiff's motion for a preliminary injunction 28 is denied as moot in light of this order. Enter Default Final Judgment Order. Civil case terminated. Signed by the Honorable Martha M. Pacold on 6/30/2023. Mailed notice

DEFAULT JUDGMENT ORDER signed by the Honorable Martha M. Pacold on 6/30/2023.

MINUTE entry before the Honorable Sheila M. Finnegan: All matters relating to the referral have been completed so the referral is closed. Mailed notice