2022-cv-06922

COMPLAINT filed by Hefei MAXYOYO Trading Co., Ltd.; Filing fee $ 402, receipt number AILNDC-20124795.

SEALED DOCUMENT by Plaintiff Hefei MAXYOYO Trading Co., Ltd. Schedule A to Complaint

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. to seal document Schedule A to Complaint and Exhibit 1 to Declaration of Shahzaib Amin Malik

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hefei MAXYOYO Trading Co., Ltd.

NOTICE by Hefei MAXYOYO Trading Co., Ltd. Notification of Claims Involving Trademarks

ATTORNEY Appearance for Plaintiff Hefei MAXYOYO Trading Co., Ltd. by Konrad Val Sherinian

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Susan E. Cox. 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.

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. for temporary restraining order

MEMORANDUM by Hefei MAXYOYO Trading Co., Ltd. in support of motion for temporary restraining order 8

DECLARATION of Konrad Sherinian

Exhibit The Counterfeit Silk Road

Exhibit Measuring the Magnitude of Global Counterfeiting

(Exhibit Binder of Unpublished Decisions)

DECLARATION of Shahzaib Amin Malik

SEALED DOCUMENT by Plaintiff Hefei MAXYOYO Trading Co., Ltd. Evidence of Defendants' Active E-Commerce Stores

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. for service by publication and electronic service

MEMORANDUM by Hefei MAXYOYO Trading Co., Ltd. in support of motion for service by publication 13

DECLARATION of Konrad Sherinian regarding motion for service by publication 13

Exhibit Hague Convention

(Exhibit Binder of Unpublished Decisions)

MAILED Trademark Request Letter to Plaintiff's counsel Konrad Val Sherinian.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

ATTORNEY Appearance for Plaintiff Hefei MAXYOYO Trading Co., Ltd. by Jeffrey Stephen Dixon

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 Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's ex parte motion to seal 3, ex parte motion for a temporary restraining order 8, and motion for service by publication and electronic service 13. Provided that Plaintiff provides the security described in paragraph 10 of the temporary restraining order, the temporary restraining order shall become effective on January 9, 2023 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 1/4/2023. Emailed notice

SURETY BOND in the amount of $ 10,000 posted by Hefei MAXYOYO Trading Co., Ltd. (Document not Scanned)

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. for extension of time on Temporary Restraining Order to Feb 6, 2023

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order 23. The Temporary Restraining Order 21 shall now expire on 2/6/2023 at 6:00 p.m. Emailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SUMMONS Returned Executed by Hefei MAXYOYO Trading Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/27/2023, answer due 2/17/2023.

Declaration Declaration of Service

(Exhibit Exhibit A to Declaration of Service)

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. for preliminary injunction

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction 26 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2 ; (2) Exhibit 2 to the Declaration of Shahzaib Amin Malik 12 ; and (3) the TRO 21. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Emailed notice

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 2/3/2023. Emailed notice.

(Add and Terminate Parties) (axc)

NEW PARTIES: Hangzhou Nianxia Wangluo Keji Youxian Gongsi, shenzhen dandingweiyu youxiangongsi, Yantai Xiaojian Dianzishangwuyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, shenzhen dandingweiyu youxiangongsi, taiyuanshijinyuanqumingjingshengshangdian, nantongtuanmeimaoyiyouxiangongsi, Hangzhou Yuanyu Import&Export Co., Ltd, nanjinghangzhouwangluokejiyouxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian and Ningboshiyuanranwangluokejiyouxiangongsi added to case caption.

ATTORNEY Appearance for Defendants HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdian by Matthew L. De Preter

(Defendant Identification)(De Preter, Matthew)

MOTION by Defendants HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdian for extension of time to Answer or Otherwise Plead - Unopposed Motion (De Preter, Matthew)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendants HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdian's unopposed motion for an extension of time to answer or otherwise plead 32. The deadline for those Defendants to file a response to the complaint is extended to 3/20/2023. Mailed notice

NOTICE of Voluntary Dismissal by Hefei MAXYOYO Trading Co., Ltd. of party shenzhenshixushengkejiyouxiangongsi

MOTION by Defendants HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdianTO DISSOLVE PRELIMINARY INJUNCTION AND FOR PROTECTIVE ORDER (De Preter, Matthew)

MEMORANDUM by HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdian in support of motion for miscellaneous relief, 35

List of Defendants

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F

Exhibit G

Exhibit H

Exhibit I

Exhibit J

Exhibit K

Exhibit L

Exhibit M - Declaration on behalf of Dr. Futon

Exhibit N - Declaration on behalf of HangUS

Exhibit O - Declaration on behalf of JinJeeo

Exhibit P - Declaration on behalf of Kiayaci

Exhibit Q - Declaration on behalf of NeuType

Exhibit R - Declaration on behalf of Nianxia

Exhibit S - Declaration on behalf of Qiqikuajingxiaodian

Exhibit T - Declaration on behalf of Softeep

Exhibit U - Declaration on behalf of S-Plus

Exhibit V - Declaration on behalf of Weiweijiadedian

(ExhibitWM - Declaration on behalf of Zella Mall)(De Preter, Matthew)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court enters the following briefing schedule on Defendants HangZhou JinYu Wangluo keji youxian gongsi, Hangzhou Nianxia Wangluo Keji Youxian Gongsi, Hangzhou ShengSheng WangLuo Keji Youxian Gongsi, Hangzhou Yuanyu Import&Export Co., Ltd, Ningboshiyuanranwangluokejiyouxiangongsi, Shenzhenshizhuohanmaoyiyouxiangongsi, nanjinghangzhouwangluokejiyouxiangongsi, nantongtuanmeimaoyiyouxiangongsi, shenzhen dandingweiyu youxiangongsi, tai yuan shi jin yuan qu xing qiu qiu shang dian, taiyuanshijinyuanqumingjingshengshangdian's motion to dissolve preliminary injunction and for protective order 35 : Plaintiff's response is due on or before 03/23/2023; Defendants' reply is due on or before 04/06/2023. Emailed notice

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's Notice of Voluntary Dismissal 38. Pursuant to Plaintiff's Notice of Voluntary Dismissal 38 and pursuant to Federal Rule of Civil Procedure 41(a), this case is dismissed without prejudice. Based on the dismissal, the Court terminates the preliminary injunction 30, and certain Defendants' motion to dissolve preliminary injunction and for protective order 35 is terminated as moot. Plaintiff is advised that in order to obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond since the preliminary injunction no longer applies to any Defendant. Accordingly, Plaintiff is directed to file a motion for the return of the bond, and to submit a proposed order to the Court by emailing a Microsoft Word version of the draft to Proposed_Order_Valderrama@ilnd.uscourts.gov. Emailed notice

MOTION by Plaintiff Hefei MAXYOYO Trading Co., Ltd. for release of bond obligation

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in Plaintiff's motion for release of bond obligation 40, the motion is granted. Enter Return of Bond Order. As all claims against all defendants have been resolved, this case is closed. Civil case terminated. Emailed notice

RETURN OF BOND ORDER: Signed by the Honorable Franklin U. Valderrama on 3/20/2023. Emailed notice