2023-cv-08005

COMPLAINT filed by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.; Filing fee $ 402, receipt number AILNDC-21026574.

Exhibit An Infringing Product Listing

Exhibit U.S. Pat. No. D980,990

Exhibit Intellectual Property Rights Seizure Statistics, Fiscal Year 2021, U.S. Customs and Border Protection

Exhibit Alibaba, Amazon, and Counterfeiting in the Age of the Internet Daniel C.K. Chow

(Exhibit Combating Trafficking in Counterfeit and Pirated Goods January 24, 2020)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Sealed Schedule A to Complaint

ATTORNEY Appearance for Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. by Depeng Bi

ATTORNEY Appearance for Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. by Konrad Val Sherinian

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.)

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. to seal Schedule A to Complaint and Exhibit 2 to Declaration of Yulin Zhou

DECLARATION of Yulin Zhou

EXHIBIT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh. 1 - U.S. Pat. No. D980,990 regarding declaration 8

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh. 2 - Stores 1-6

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh. 2 - Stores 7-11

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 12-17

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 18-24

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 25-30

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 31-36

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 37-44

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 45-51

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 52-59

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 60-66

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 67-73

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 74-79

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for leave to file under seal 7 is hereby granted. Mailed notice.

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 80-85

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 86-91

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 92-97

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 98 - 103

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 104 - 109

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 110 - 116

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 117 - 123

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 124 - 132

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 133 - 140

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 141 - 149

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 150 - 157

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 158 - 163

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 164-170

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 171 - 177

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 178 - 185

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 186 - 194

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 195 - 204

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 205 - 215

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 216 - 222

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 223 - 229

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 230 - 236

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 237 - 243

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 244 - 250

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 251 - 260

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 261 - 271

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 272 - 281

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 282 - 292

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 293 - 306

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. Exh 2 - Stores 307 318

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for temporary restraining order

MEMORANDUM by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. in support of motion for temporary restraining order 52

NOTICE of Motion by Konrad Val Sherinian for presentment of motion for temporary restraining order 52 before Honorable Charles P. Kocoras on 9/19/2023 at 09:30 AM.

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for leave to file excess pages

NOTICE of Motion by Konrad Val Sherinian for presentment of motion for leave to file excess pages 55 before Honorable Charles P. Kocoras on 9/19/2023 at 09:30 AM.

DECLARATION of Konrad Sherinian regarding motion for temporary restraining order 52

Exhibit Exh 1 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 2 - Hague Convention

Exhibit Exh 3 - Civil Procedure of the People's Republic of China

(Exhibit Binder of Unreported Cases)

MINUTE entry before the Honorable Charles P. Kocoras: This case will be referred to the Executive Committee for reassignment by lot to a District Court Judge.

EXECUTIVE COMMITTEE ORDER: IT IS HEREBY ORDERED that the above captioned case be reassigned by lot to the calendar of an individual judge of this Court in accordance with the Rules. Case reassigned to the Honorable Lindsay C. Jenkins for all further proceedings. Honorable Charles P. Kocoras no longer assigned to the case. Signed by Executive Committee on 09/12/2023.

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for leave to file excess pages 55 is granted. By September 18, 2023, Plaintiff shall submit a proposed TRO Order to the Court's proposed Order box: proposed_order_jenkins@ilnd.uscourts.gov. The September 19, 2023 notice date 56 is stricken. Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. (Document not scanned).

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for extension of time Extend TRO to October 17, 2023

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion to extend the TRO 64 is granted. TRO is extended to October 17, 2023. Mailed notice.

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.Electronic Service of Process

DECLARATION of Konrad Sherinian regarding motion for miscellaneous relief 66

Exhibit Exh 1 - Hague Convention

(Exhibit Exh 2 - Binder of Unpublished Decisions)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for electronic service of process 66 is granted. Separate Order to issue. Mailed notice.

ORDER Signed by the Honorable Lindsay C. Jenkins on 10/3/2023. Mailed notice.

SUMMONS Returned Executed by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. as to Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. on 10/3/2023, answer due 10/24/2023.

(Declaration Declaration of service)

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for preliminary injunction

MEMORANDUM by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. in support of motion for preliminary injunction 71

DECLARATION of Konrad Sherinian regarding motion for preliminary injunction 71

(Exhibit Binder of Unreported Decisions)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 71 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by October 10, 2023." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. 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. Mailed notice.

DECLARATION of Depeng Bi

(Declaration Declaration of service)

DEFENCE OPINION by The Partnerships and Unincorporated Associations Identified on Schedule A

MOTION by Defendants Zhouxiangni, ARTLATU, Ganzhoujingjijishukaifaquhailongbaihuoshanghang, Cevilia S to set a briefing schedule re: Dkt. 71

ATTORNEY Appearance for Defendants ARTLATU, Cevilia S, Ganzhoujingjijishukaifaquhailongbaihuoshanghang, Zhouxiangni by Adam Edward Urbanczyk

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants' Zhouxiangni, ARTLATU, Ganzhoujingjijishukaifaquhailongbaihuoshanghang, and Cevilia S's motion for a briefing schedule on the preliminary inunction motion is granted. These Defendants' response to the motion is due by October 17, 2023 and any reply is due by October 24, 2023. If Plaintiff objects to providing these Defendants with the relevant material (such as the sealed material contained at [4, 10-51]), Plaintiffs must file a written objection with the Court by October 13, 2023, and the Court will reset the preliminary injunction briefing schedule. Mailed notice.

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

ATTORNEY Appearance for Defendant Wayuen by Adam Edward Urbanczyk

RESPONSE by Wayuenin Opposition to MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for preliminary injunction [71]

Exhibit 1

Exhibit 2

Declaration of Chu Weiwei

MOTION by Defendant Wayuen for extension of time to file response/reply as to response in opposition to motion, [82]

EXHIBIT by Defendant Wayuen 1 (translated) regarding response in opposition to motion, [82]

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Wayuen's motion for extension of time to respond [83] is granted. Mailed notice.

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

REPLY by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. to motion for preliminary injunction[71]

Exhibit Infringement of Accused Product

DECLARATION of Yulin Zhou regarding motion for preliminary injunction[71]

DECLARATION of Depeng Bi regarding motion for preliminary injunction[71]

Exhibit Email from Attorney

Exhibit Reply Email from Attorney

Exhibit Email to Adam Urbancyzk

Exhibit Request to Issue Certificate of Correction

Exhibit Exh 5 - Binder of Unpublished Decisions

ANSWER to Complaint by Wayuen

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Wayuen has filed an opposition to the motion for a preliminary injunction, and this Defendant is the only one who has filed a brief by the October 17, 2023 opposition deadline. Wayuen's opposition does not contest infringement. Instead, Wayuen's primary argument is that Plaintiff has not shown a likelihood of success on the merits because U.S. patent No. D980,990 (the "'990 Patent") is vulnerable to being invalidated because the named inventor did not invent the claimed design. [Dkt. 82 at 2.] Plaintiffs' reply brief has explained that a petition for a certificate of correction has already been filed to correct the names of the proper inventors, and there is no reason for the Court to doubt that the appropriate correction will be made by the PTO under 35 USC 256(a). Thus, the Court grants the preliminary injunction motion [71] for the reasons stated in its Order granting the TRO. Separately, Defendant argues that the asset restraint should be reduced to $242.58, which is the revenue of its sales of the accused products. Plaintiffs ask the Court to reject Defendant's declaration submitted in support of this figure, which asserts that Defendant's store owner only made a limited number of sales. The Court is inclined to reduce the asset restraint on Wayuen. To resolve this issue, the parties are directed to conduct expedited fact discovery to determine the full extent of Defendant's sales and profits. A proposed fact discovery deadline is to be filed by November 2, 2023. Plaintiffs are directed to submit a revised preliminary injunction order to the Court's proposed order mailbox by October 27, 2023. Mailed notice.

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

MOTION by Plaintiff Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd. for default judgment as to certain defendants

MEMORANDUM motion for default judgment[93] by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

Exhibit List of Defaulting Defendants

DECLARATION of Konrad Sherinian regarding motion for default judgment[93]

MINUTE entry before the Honorable Lindsay C. Jenkins:As previously stated, Plaintiff's motion for a preliminary injunction [71] is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established [75] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, and the Court has overruled the objection filed by Defendant Wayuen. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The The Law Offices Of Konrad Sherinian, LLC., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Lindsay C. Jenkins on 10/27/2023. Mailed notice.

LETTER.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following does not apply to Defendant Wayuen. Before the Court is Plaintiff's motion [93] for entry of default and default judgment against certain Defendants. The defendants listed in the motion have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before November 6, 2023. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service pursurant to the order of Dkt. No. 99 by Depeng Bi on behalf of Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

APPLICATION by Wei Wei for Additional Evidence.

ATTORNEY Appearance for Defendant LiSeng by Jiyuan Zhang

MINUTE entry before the Honorable Lindsay C. Jenkins: Two letters have been filed on the docket at [98], [101]. The Court disregards these filings, in part because the Court has no way of determining who filed the letters or on whose behalf they were filed. The letters do not otherwise comply with the Federal Rules of Civil Procedure because no appearance or responsive pleading by counsel has been filed on behalf of the entities named in the letters. The deadline for any objection to the pending motion for default remains set for November 6, 2023. Mailed notice.

NEW PARTIES: 50/50 Split.inc and chucangs added to case caption. (Text entry; no document attached.)

NEW PARTIES: Femdela, Concon Ai, UandPStore, KANGQIUPINGWAND, PeachBlossomPeachBlossom, QUWEX, TANGHAILONG, Chichch, JG-JHY, shanxituoyangsishishangmaoyouxiangongsi, AiLaiKe, Vottrin, chunyunwei, Xiechaobing, VELLHTV, fdsfgydsofyhsuidghdfhgfodigjn, AQLDou, A2ZK706QYMNOO5, dinganzhexiaoyushangmaoyouxiangongsiaaxgsax, SKDDP1, DAUOO-US, Darieljr, suitable for all, MARTURASCA, Ruiyiya, SD-07B, BBlison, ssfmy-us, Ying Zi Ran and Shenzhenxiangweiyouxuannongyekejiyouxiangongsi added to case caption. (Text entry; no document attached.)

NEW PARTIES: Longtongshun, yuexingwangkeji, Inew Fashion, JOJOMY, Topabest, JZ JAUZ, WMYone, FSZMan, HXCG-GCWD, ZHJUYAN, SPINEX, yayay13953, qujiajia, Hongqiaodianzi, wuqiangbao, FOXTSPORT, GexruDirect, Tastlinder, RonFin US, AGEJIPKO74LU1, Adrxmexna Story, Yiku Express, DOULAIXIADAN, yaojiang668, The Right Supps, BLACKBORZ, L1YA, CloudTrip, MVBOONE, JUHAN-US, TianYaOutDoor, Bengbu Hehong Trading Co., Ltd., jinuopenh062, anxixianhuqiuzhenlinsongjiabaihuoshanghang, Catephe, amamll, availr, LesspriceWZD, hajnbdtv, huangyajuan23 and Aqianduoduo added to case caption. (Text entry; no document attached.)

NEW PARTIES: ziyouti, Topcat Goods, Tomlila, huangkaixindemeiguodian, SUSH-NH, MuXueBinJiaJu, REF STORE, ISMETACU, Elegantshop.USA, ExcelPorm, Ds all Zhan, Ompelluss, SOYATER-US, SUMPOL Co.,Ltd., Zoboofil, tdyzbao, JMsmile Store, Rezend, Velocity Logistic, HF Tech, 7-14 days deliver-FY Innovation Factory Co., NZMV, ESSENTIAL WAREHOUSE LLC, ComeTrue, QianMaiDai, YlovepetUS, POULA, Luxclass, Bravtrops, Kelonkt, JinTan tech Co, hehongjiandedian, M S Shopping Malls, LYYHMAY-US OFFICIAL, Chujia, yueyi520, Fanster Technology, chivalral, Tbusingoto, Walchwil4ever, changchunshiyuanluoyanshangmaoyouxiangongsiabbc and WAPAL added to case caption. (Text entry; no document attached.)

NEW PARTIES: ProductFrancis, YINYUAN-XQZT, Pekai, Great Deals Finder, kesheng-jwb, SCPET Direct, Thank the Plank, woodone, Ping LI, Nancy's Grocery Store, SHAHIN BABA, A25QP5FTEPQI6J, maxime auto, Yishunjian, Secreto Wear, XINET, fuzhoushigulouqudonglaidongwangbaihuoshanghang, makesky-tec, Trusted quality control, LOTIFIE, SEICIPET, QDDJGYP Jewelry, Ears Up Pup, Guanyuetong, siguanda, Demandartprint, gugder SMI, Baosity, Yunt-us, Amazon Global Store UK, PriceXes, ailianbaihuodian, PHSXD, songshanquyoubaihuobaihuochaoshi, A14U4T3U914DBX, zhangfangmingdedianpu, xuanjingongsi, XiaoXiangYangXiaoDian, Acusu, DDBR.LLC and bestcost added to case caption. (Text entry; no document attached.)

NEW PARTIES: Justing8888, LLOVEJMP, Funankelin, Colaxius, POPLOVECARD and FYK-US added to case caption. (Text entry; no document attached.)

NEW PARTIES: A&D Retailers, EveryDayGoodsToGo, A3A63TZS4HY8LH, TYDHO, Linyh, Houmt-USA, Hullsyll, lotute, Junior Collegee, ZhiShuo, MuShiHui123, JYF boutique store, XianYouXianLiChengMuGuangBaiHuoShangHang, TheLittleGenie, qingyushe, FAWGWML, LEAQU, lankangshanghang, AA7W540VEZ0H1, ou mei qing, meilinhua, KOUMSTORE, Banssy, Awei-Store, gQBm, yimayuxiang, ZHANGYAN123, zhiqiuh, AX59UPSWEP5HK, JiaLu BaiHuo, SUNNIMIX, motokitio, DYNWAVE US, Shuyi Sp shop, Rarido, RZJZGZ, Kayden88, JKCL, Hobeda, shenglan rizhao, HOFUDA, Hekisace, VELINE, BARBARIC GROWTH, shanxilengyixueshangmaoyouxiangongsi, HalalDeals and Danmus Official added to case caption. (Text entry; no document attached.)

NEW PARTIES: DAGUYS, yayukeji, guangzhouqingjianshangmao, A3U8FYJCEQ5N2H, koumindedianpu, Quality care1, xczc19, Ciliefaley1, JMsmileStore, sunyuchidedianpu, AnBety, MO&JO, yudengluowangshangmao, QuickShopEssentials, be_yours, yongchunweikemaoyiyouxiangongsi, BUY TIME 314, slowfeed, xiaolingll690, CMARS, Durakhshon, bqbqbq-113, Topmood, TBTFW shop, Tianang Technology, Stay Classy LLC, NNNOIHU, Labibida, Potato Shop, BUGAY DI DUKAN, SRKLH, Y&C eTrade, Mengcan Trading, huichuangchuandongkejiyouxiangongsi, OneClicker, deniaoshangmao-US, Hu Ba Department Store, LINqi, facith, HSBETERLIF, Lartoo, mixinsy, meilinghub, HeRanDianZi, Wolmik Fashion, shuaishuaid, YUE chuang, Hubobo, RUS MARKET, dalichengmaoyiyouxiangongsi, XUYONGWANGCHANGBAO, YINGGEHUN and VSNPO added to case caption. (Text entry; no document attached.)

NEW PARTIES: LIUYA, Teritre, Shengyao Store, yuanyuan230498, Xiao Zheng, hefeituantashangmaoyouxiangongsi, Houpu Flagship Store, WACUS, Yubin Chen, PANDA YU, chongxunmaoyi12, duchanglijia, shuozhoushiyujiangshangmaoyouxiangongsi, binzhouliangwanqiangwangluokejiyouxiangongsibm, hongzhixingde, Uilisoil, The Shean, ATMGC, Daxing Department Store, Jusen Magic House, Annie, pingdingshanshihaomeifulongshangmaoyouxiangongsi, HKYL, luck868123, Yunlongbm, ATMGA, Hunan shiyuanda Trade Co., Ltd, Ghost 3D, YONGDD, kedongrun, Shi Mu Yue Pin Department Store, Happy Macchiato, woanqh store, promise-b, chengduyonglunguangshangmaoyouxiangongsi, payaw, ZHANG YING SHOP, BESIBOO, ATMGO, boltt express, Happy Freshener, kunyangshanghang, zhongxiangch660 and DAGJISDSKUSHV-US01 added to case caption. (Text entry; no document attached.)

MAILED Patent report to Patent Trademark Office, Alexandria VA.

Patents

MOTION by Defendant LiSeng for extension of time to file answer regarding complaint, [1], text entry, [96] and oppose to Plaintiff's motion for default judgment [Dkt 93]

Unopposed Proposed Discovery Schedule for Defendant Wayuen by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Elec-tronic Commerce Co. Ltd.

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant LiSeng's motion for extension of time to oppose default and to answer [105] is granted. Given that an appearance for LiSeng was filed on 10/31/23 and now that a motion for extension of time has been filed, the Court concludes it is appropriate to grant Defendant LiSeng until November 30, 2023 to answer or otherwise plead. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court adopts the discovery schedule proposed by the remaining parties. Plaintiff may serve written discovery and Defendant's response is due by November 10, 2023; the parties are to meet and confer by or before November 21, 2023 and Plaintiff should file a statement with an updated asset freeze amount together with any supporting documentation by December 5, 2023. If the amount is disputed or if a motion to compel is necessary, Plaintiff's statement should include a proposed briefing or response schedule. Mailed notice.

STIPULATION of Dismissal of store LiSeng, Def. No. 7

MINUTE entry before the Honorable Lindsay C. Jenkins:The following Order does not apply to Defendants Wayuen or LiSeng. The remaining Defendants have not responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [93] is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants, the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that an award of statutory damages. Enter partial default judgment. Mailed notice.

PARTIAL DEFAULT JUDGMENT ENTERED Signed by the Honorable Lindsay C. Jenkins on 11/8/2023. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: LiSeng terminated. Mailed notice.

FULL SATISFACTION of Judgment as to Def. Nos. 26, 32, 56, 70, 73, 88, 129, 134, 141, 142, 148, 167, 174, 223 and 235

FULL SATISFACTION of Judgment Def. Nos. 10, 16, 24, 34, 43, 44, 97, 117, 118, 132, 202, 249, 311 and 228

STIPULATION of Dismissal of store Wayuen

MINUTE entry before the Honorable Lindsay C. Jenkins: A stipulation of dismissal [116] has been filed as to the last remaining Defendant, Wayuen. Civil case terminated. Mailed notice.

FULL SATISFACTION of Judgment stores Houpu Flagship Store, AiLaiKe, CMARS, meilinghub and Justing8888

FULL SATISFACTION of Judgment store The Right Supps

FULL SATISFACTION of Judgment store MuXueBinJiaJu

FULL SATISFACTION of Judgment

FULL SATISFACTION of Judgment store L1YA