2022-cv-07031

COMPLAINT filed by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited; Filing fee $ 402, receipt number AILNDC-20140453.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

SEALED EXHIBIT by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited Schedule A regarding complaint, [1]

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Manchester United Football Club Limited

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tottenham Hotspur Limited

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Liverpool Football Club and Athletic Grounds Limited

Notice of Claims Involving Trademarks by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Andrew Daniel Burnham

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited in support of motion for temporary restraining order, [15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Laura Harrington regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

DECLARATION of Matthew Collecott regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

DECLARATION of Paul Dicken regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited Exhibit 3 - Parts 1-9 regarding declaration[19], declaration[20], declaration[18]

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limitedfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited in support of motion for miscellaneous relief[22]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[23]

Exhibit 1

Exhibit 2

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited Establishing that Joinder is Proper

Declaration of Justin R. Gaudio

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's motion for leave to file under seal 3, ex parte motion for a temporary restraining order 15, and motion for electronic service of process 22. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on December 28, 2022 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 12/22/2022. Emailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

BOND in the amount of $10,000.00 company check, Receipt No. 4624280678, posted by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited (Text entry; no document attached.)

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.

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for extension of time of Temporary Restraining Order

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited in support of extension of time 29

(Declaration of Justin T. Joseph)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order [29]. The Temporary Restraining Order [29] shall now expire on 1/25/2023 at 6:00 p.m. Emailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 1/10/2023. Emailed notice

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Trevor Christian Talhami

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for preliminary injunction

(Exhibit A)

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited in support of motion for preliminary injunction 34

Declaration of Justin T. Joseph

(Exhibit 1)

SUMMONS Returned Executed by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/20/2023, answer due 2/10/2023.

Declaration of Justin T. Joseph

(Exhibit A)

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 34 is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint 2, (2) Exhibit 3 to the Declarations of Laura Harrington, Matthew Collecott, and Paul Dicken 21, and (3) the Temporary Restraining Order 27. Greer, Burns & Crain, Ltd. is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instruction can be found in the attachment to this entry. Emailed notice.

(Add and Terminate Party) (axc)

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 1/23/2023. Emailed notice

NEW PARTIES: ANNISOUL-Fashion Store, Bandai Anime Diamonds Painting Factory Store, Blessing Sticker House, Brittany Store, Building Bricks Funny World Store, CEEM Store, Cisley Store, CP Toys Store, DECAL YANG 0601 Store, Decor Gallery Store, Dojoke Store, EASYLITE Official Store, funbeads Store, HEYI Official Store, HIHIHI Store, HT life Store, Interesting Art Store, JAY2022 Store, Judy baby Store, LANGRU Store, Leyao Official Store, Linxiaofei Official Store, Lovewall decor Store, LovinHouse Store, LY wall stickers Store, miliblanket Store, Mr hi wall sign Store, naifei Official Store, One Piece Anime Dragon Ball Diamond Painting Store, Painting decoration company Store, rick canvas Store, Rustom Decor Store, Shop1100082150 Store, Shop1100083211 Store, Shop1102059444 Store, Shop1102063397 Store, Shop1102135085 Store, Shop1102195286 Store, Shop1102271223 Store, Shop1102292219 Store, Shop5421041 Store, Shop5618337 Store, Shop5952120 Store, Shop910322020 Store, Shop910332291 Store, Shop910359286 Store, Shop911068171 Store, Shop911223068 Store, shuai rao D-I-Y diamonds painting Store, Suntey Store, Swallow Art Store, Tesco Painting Store, TGIF Art Store, TONGLING BEAUTIFUL ART Store, Wienen decoration painting Store, Win-Win Decor Store, XFRYJIA paintings Official Store, XuanYF ART Store, Yao De Fang Store, YaoBo factory Store, YINGWEN DIAMONDS PAINTING Store, YOSLIFE Store, ZALAA Store, Zhou Smoothly Store, A3OQ6KKNPNWFZ3, AAFVKRNHIADHC, Amaz0.c0m, ATSKY, BAGTTA, Bdkter, bianhengqiang, CE90E, changqianqian001, chenlanwadwd, CHENLINBAIHUO, CoCeng, Colortop-yanjie230, Creative home life hall, DAMEIZS, Damshine, Deertweet Home, duanliboalksdjflkj, Duuloon, EinZoy, enyouxiaodian, evsep, fangzi-building, FLWIFJOIASFHJAOIHUFIAUF, FLWIJFOIASJFOIASFHUIAHFU, Fwvbe, FXIXI, great artist, haibaozhijia, haikouzhushanshanshangmaoyouxiangongsi, Himoop, HKTianCaiXia, HKZhangLi, HONG KONG FENGYE CO., LIMITED, HouSerin, Houseuse, huangdan0001hd, ianlikejiyouxiang, jianhckuo, JIPEIZI, juncanshangmao, junwen art, Kcweet, keepbiggestpower, kizcx, KunMingYangXiWenDianZiShangWuYouXianGongSi, Lakinmo, lilizhenzz, LLXD, NanPingShiJianYangQuLinNongZhouXuanBaiHuoDian, Oem81e, OkamiD, Painting Home, PEC32U, PISTER, POIYEa, QINTANSM, Roodina, Rosalinda Gonzales, rovuuc, shanxilingzhenyifeishangmaoyouxiangongsi, Soccergame-example 1, TangXinShop, tcsnu, TheTotelwellbeing, ThLeoPo, tkook, tmppo, tunkang651, Upmarip, Varost, ver39, Vintage Tin Plaque, VRXKE, Walomes, WDJM, weiguocunfuwu, WesQi, WJQ Shop, WQFuS, WUDONG Store, WUFIFIVE5, WYOUCHENG, XCSPY, xiang-ling, XIAOHANGXIAO, XJYI, xvtuy, Yinaa_Decor, Yunmai Store, Zanjke, Zapion, zhangjinjin STOR, ZHANGTAOZHE, zhanyokdx, zhengweihan, zhizui, ziyifushi, zriob, ZZYuni, amy1003_1 Store, andy8886 Store, best_jerseys_store Store, cartss Store, hulk_sports Store, isoccer Store, jerseys_2022 Store, jerseys_sport Store, jing110629 Store, powerjersey804 Store, soccer jersey131129 Store, soccerjersey6998 Store, soccerjerseys2223 Store, soccershop1688 Store, spider_jerseys Store, tomato2022 Store, urjerseymall Store, world_jersey2022 Store, yakuda Store, backpack2022, cleos-98, hewe-715, liyong-2268, onewatchfallsinlove, rangeek021, wanghon-76, DD's Home, Putian Duolian Shangmao Youxian Gongsi, shenzhenshi baoma dian zi shang wu you xian gongsi, royal-sports.x.yupoo.com and stevenlholm added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendants

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain Defendants

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for entry of default, MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited in support of motion for entry of default, motion for default judgment, [42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion, [43]

Exhibit 1

ATTORNEY Appearance for Defendants TangXinShop, WJQ Shop by Christopher Paul Keleher

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendant

MOTION by Defendants TangXinShop, WJQ Shop for extension of time to file answer UNOPPOSED

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendants TangXinShop and WJQ Shop's unopposed motion for an extension of time to answer or otherwise plead [47]. The deadline for Defendants TangXinShop and WJQ Shop to file a response to the complaint is extended to 3/6/2023. Mailed notice

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendants

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed Plaintiff's motion for default judgment as to all Defendants 42. Based on recent filings and the dismissals of certain Defendants, Plaintiff is directed to file an amended Schedule A to its motion for default judgment. The Court defers ruling on Plaintiff's motion until the amended Schedule A is filed. Emailed notice

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendants

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to a certain Defendant

AMENDED exhibit[2] Amended Schedule A

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited to approve consent judgment as to a certain Defendant

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's motion to approve consent judgment 54 is denied. Plaintiff asks this Court to enter and approve a consent judgment concerning a settlement between Plaintiff and one Defendant, shenzhenshi baoma dian zi shang wu you xian gongsi (Defendant No. 193), out of a total of 195 Defendants named in this lawsuit. Plaintiff has also included Defendant No. 193 in its Amended Schedule A 53, and has asked the Court to enter a default judgment against that same Defendant 42. The motion to approve consent judgment itself is entirely threadbare, and does not explain to the Court why Plaintiff is seeking the requested relief. The parties could simply file a notice of dismissal or a stipulation of dismissal under Rule 41. Plaintiff must come forward with a good reason if they want this Court to enter a consent judgment. Schedule A cases impose extraordinary burdens, so counsel must make every effort to minimize those burdens on the judiciary. The Court suggests a notice or stipulation of dismissal under Rule 41, and filing an Amended Schedule A to reflect dismissal of Defendant No. 193, because the Court sees no compelling need to impose additional burdens on the judicial process. Emailed notice

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for reconsideration regarding order on motion to approve consent judgment, text entry, [55]

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: On 02/21/2023, the Court granted Defendants TangXinShop and WJQ Shop's unopposed motion for an extension of time to answer or otherwise plead, extending that deadline to 3/6/2023 [48]. To date, Defendants TangXinShop and WJQ Shop have not filed any answer or other responsive pleading. The Court gives Defendants TangXinShop and WJQ Shop until 3/23/2023 to answer or otherwise plead. Failure to file a responsive pleading by that extended deadline may result in default judgment against those Defendants, as the Court is inclined to grant the motion for default judgment as to all remaining defendants, including represented defendants. Emailed notice

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiffs' motion for reconsideration of order denying Plaintiffs' motion for entry of a consent judgment [56] is granted. Enter consent judgment order. Pursuant to the consent judgment order, Defendant shenzhenshi baoma dian zi shang wu you xian gongsi (Defendant No. 193) is dismissed without prejudice with leave to reinstate Defendant No. 193 on or before 09/11/2023, at such time, absent a motion to reinstate, shall automatically convert to a dismissal with prejudice. Emailed notice

CONSENT JUDGMENT: Signed by the Honorable Franklin U. Valderrama on 3/15/2023. Emailed notice

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendants

MOTION by Attorney Christopher Keleher to withdraw as attorney for TangXinShop, WJQ Shop. New address information: Lin Haung, Room 497, Floor 1, No 33, Shuanglong St, Meilin Town, Ganxian District, GanZhou, JiangXi, China, 341000

Declaration Notification of party contact information

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Defendants' TangXinShop and WJQ Shop's unopposed motion to withdraw counsel [61] is granted. Defendants' TangXinShop and WJQ Shop have 30 days, until 04/20/2023, to retain new counsel. The Court notes that corporations are not permitted to represent themselves in federal court. See 1756 W. Lake St. LLC v. Am. Chartered Bank, 787 F.3d 383, 385 (7th Cir. 2015) (noting the "requirement that a limited liability company be represented in litigation by a lawyer"); Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851, 858 (7th Cir. 2011) ("[C]orporations must appear by counsel or not at all.") Failure to obtain substitute counsel by the date set forth above may subject TangXinShop and WJQ Shop to the entry of default and default judgment. The Clerk of the Court is directed to update TangXinShop and WJQ Shop's contact information to Lin Haung, Room 497, Floor 1, No 33, Shuanglong St, Meilin Town, Ganxian District, GanZhou, JiangXi, China, 341000, as stated in docket [61-1]. By 03/24/2023, withdrawing attorney Christopher Keleher must: (a) serve a copy of this order on a TangXinShop and WJQ Shop's representative; and (b) file a certificate of compliance on the Court's docket stating that counsel has done so. The Court advises Defendants TangXinShop and WJQ Shop that Plaintiffs have filed a Motion for Default Judgment against them [42]. Defendants TangXinShop and WJQ Shop were given an extension to answer or otherwise respond to the Complaint on 02/24/2023 [50] until 03/06/2023 and, sua sponte, until 03/23/2023 when no answer or other responsive pleading was filed by that extended deadline [57]. To date, Defendants TangXinShop and WJQ Shop have not filed any answer or other response. The Court again extends the time for Defendants TangXinShop and WJQ Shop to answer or otherwise respond to the complaint by 04/20/2023. Failure to file an answer or other response on or before that deadline may result in entry of default judgment against TangXinShop and WJQ Shop. Emailed notice

CERTIFICATE of Compliance

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendant

NOTICE of Voluntary Dismissal by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited as to certain defendants

MINUTE Entry before the Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against the Defendants Identified in Schedule A 42 is granted. Enter Final Judgment Order. The ten-thousand-dollar ($10,000.00) cash bond posted by Greer Burns & Crain Ltd., including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the cash bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 4/28/2023. Emailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA