2023-cv-15822

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-21316271.

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 The Liverpool Football Club and Athletic Grounds Limited

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tottenham Hotspur 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 Trevor Christian Talhami

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.

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2).

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, [13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Laura Harrington regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

DECLARATION of Paul Dicken regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

DECLARATION of Matthew Collecott regarding memorandum in support of motion[14]

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 1-7 regarding declaration 17, declaration 16, declaration 18

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

(Exhibit 3-7)

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for 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[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 are set for a telephonic motion hearing on 11/21/2023 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 11/21/2023. For the reasons stated on the record, Plaintiffs' ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 are taken under advisement. Plaintiffs' motion for leave to file under seal 3 is granted. The Clerk is directed to maintain the following documents under seal until further order of this Court: (1) Schedule A to the complaint 2, and (2) Exhibit 3 - Parts 1-7 19. Telephonic status hearing set for 12/5/2023 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Andrea R. Wood: Telephone status hearing held. As discussed on the record, Plaintiff shall submit either (1) a position paper stating Plaintiff's basis for asserting joinder of the subject trademark claims by the three plaintiffs under Fed. R. Civ. P. 20(a)(1), particularly in light of the number of defendants; or (2) or an amended complaint by 12/12/2023. A telephone status hearing is set for 12/20/2023 at 11:00 a.m. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

AMENDED complaint by The Liverpool Football Club and Athletic Grounds Limited against The Partnerships and Unincorporated Associations Identified on Schedule A and terminating Manchester United Football Club Limited and Tottenham Hotspur Limited

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Amended Schedule A regarding amended complaint, [28]

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery - Amended

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Amended Exhibit 3 - Parts 1-5 regarding exhibit, [19]

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) Amended

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 12/20/2023. For the reasons stated on the record, Plaintiffs amended ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery [30], and amended motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [32] are granted. Enter Sealed Temporary Restraining Order. The Temporary Restraining Order is entered effective 11:00 a.m. on 12/20/2023 and shall expire in fourteen (14) days. It is further ordered that Plaintiff shall deposit with the Court ten thousand dollars ($10,000.00) as security, determined adequate for the payment of such damages as any person may be entitled to recover as a result of a wrongful restraint hereunder. Plaintiffs ex parte motion for entry of a temporary restraining order, including a temporary injunction, temporary asset restraint, and expedited discovery [13], and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [20] are terminated as moot. Telephonic status hearing set for 1/3/2024 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Andrea R. Wood on 12/20/2023. Mailed notice

SUMMONS Issued as to The Partnerships and all other Defendants identified in the Complaint

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for extension of time of Temporary Restraining Order

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of extension of time[35]

Declaration of Justin T. Joseph

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 12/28/2023: Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by The Liverpool Football Club and Athletic Grounds Limited.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's ex parte motion to extend the temporary restraining order 35 is granted. The Court finds good cause to extend the temporary restraining order an additional 14 days to 1/17/2024. Telephonic status hearing set for 1/3/2024 is stricken and reset for 1/17/2024 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to Certain Defendants

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction

Exhibit A

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for preliminary injunction[41]

Declaration of Justin T. Joseph

Exhibit 1

SUMMONS Returned Executed by The Liverpool Football Club and Athletic Grounds Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/11/2024, answer due 2/1/2024.

Declaration of Trevor C. Talhami

Exhibit A

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of a preliminary injunction 41 will be heard at the telephonic hearing set for 1/17/2024 at 9:15 AM. Any person wishing to be heard on the motion shall file an appearance and contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 1/17/2024. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [41] is granted. Enter Preliminary Injunction Order. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint [2],[29], (2) Exhibit 3 [19],[31], and (3) the sealed temporary restraining order [34]. Plaintiffs' counsel is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Telephonic status hearing set for 3/5/2024 at 9:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Andrea R. Wood on 1/17/2024. Mailed notice

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to certain defendants

NEW PARTIES: High Quality Household Products Store, Licoco Store, Shop1102772389 Store, Shop1102876584 Store, XYXINYI Store, A1VHLLCYZUZ4NL, A2IU6X7SZGYP53, A3RYMSJSPR846J, AIOFGHALK, Ashtton, AU1DNA2HE2TMV, caironglujshdjh, Carty CLL, chengduchaocongjishangmaoyouxiangongsi, chongqingjingxinyuejiajuyouxiangongsi, chongqingqiangwenwujinyouxiangongsi, Dracey store, ghuangangsh, Happy day Store, hefeizhunshenwangluokejiyouxiangongsi, hongdonghuafanmaoyiyouxiangongsi, Hongming Art, JIAN PIN, kilibuy, KOKO-NONO, LiWenChao123, LU SIGN STORE, MA8QR8A91U, na sport soccer, qinglongmaoyishanghang, RenQingLiang123, SDNJH WSHX LLC, shenweididianzishangwuyouxiangongsi, song soccer sport, TOMOYOUKI storefront, unqinshangmaoy, VecNum, wangliqingongyipinyingshuadian, WeiKuo MinZai, Xiamenchuangxiamimitiyuwenhuayouxiangongsi, xiandandingmaoyiyouxiangongsi, xiangkaiplus, XiaoSuKe, xiongyuhang123, Yaira Jef, YTGGYTTYCC, zhanghuajianbeimeizhan, zhengaipinggongyipindian, fenfachengjin, cathy.7710, wwj688, AB Decor wall art, annisrx9, Voarch-US, Ann Schmidt, artesana siempre-mas, Bright life, canvaswallartposter, Elegant poetry one, gepu shop, Joel Moreno, kaige fashion, Ladies hot fashion, love yu, Nnoicoje, Sheng Tang520, uhgasfaqhgsrfafs, yueqsa and zhangzhenning fashion added to case caption.

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to certain defendant

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for entry of default as to all Defendants, MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for default judgment as to all Defendants

Exhibit A

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for entry of default, motion for default judgment, [49]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[50]

Exhibit 1

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against all remaining Defendants 49 will be heard at the telephonic hearing set for 3/5/2024 at 9:00 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to certain defendant

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to certain defendant

ATTORNEY Appearance for Defendant Happy day Store by Adam Edward Urbanczyk

MOTION by Defendant Happy day Store for extension of time

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 3/5/2024. For the reasons stated on the record, the Court enters Rule 55(a) default against all remaining Defendants, with the exception of Defendant Happy day Store. Plaintiffs' request for entry of default judgment [49] is taken under advisement. Defendant Happy day Store's motion for extension of time [56] is granted. Defendant Happy day Store shall answer or otherwise respond to Plaintiffs' complaint by 3/26/2024. Telephonic status hearing set for 4/2/2024 at 9:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 4/2/2024. For the reasons stated on the record, the Court enters Rule 55(a) default against Defendant Happy day Store. The Court will rule on Plaintiffs' request for entry of default judgment [49] in short order. Telephonic status hearing set for 4/17/2024 at 9:30 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Plaintiffs' request for entry of default judgment [49] is granted. Plaintiffs shall submit an updated proposed default judgment order within 24 hours. Telephonic status hearing set for 4/17/2024 is stricken. Civil case terminated. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA