2023-cv-15915

COMPLAINT filed by JANE DOE; Jury Demand. Filing fee $ 402, receipt number AILNDC-21325500.

Exhibit 1

Exhibit 2

Exhibit Schedule A

(Civil Cover Sheet)

ATTORNEY Appearance for Plaintiff JANE DOE by Xiyan Zhang

ATTORNEY Appearance for Plaintiff JANE DOE by Pete Scott Wolfgram

SEALED MOTION by Plaintiff JANE DOE

Text of Proposed Order

Exhibit 1A

Exhibit 1B

Exhibit 1C

Exhibit 2

Exhibit Schedule A

(Exhibit Unredacted Complaint)

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 1).

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.

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff has proceeded anonymously. The Seventh Circuit heavily disfavors anonymous, pseudonymous, or "no-name" litigation and requires the plaintiff to demonstrate "exceptional circumstances" that justify a refusal to self-identify. Doe v. Village of Deerfield, 819 F.3d 372, 37677 (7th Cir. 2016). "[B]rand owners who seek relief against alleged counterfeiters may be frustrated by the stringent requirements for pseudonymous litigation. But in the absence of a change in binding Seventh Circuit caselaw, changes to the Federal Rules of Civil Procedure, or the creation of an alternative legislative remedy, the current legal framework does not permit pseudonymity without a demonstration of circumstances more exceptional than those presented" in a typical schedule A case. XYZ Corp. v. Partnerships and Unincorporated Associations Identified on Sched. A, No. 21-CV-06471, 2022 WL 180151 (N.D. Ill. Jan. 20, 2022). To proceed, the plaintiff must show cause why exceptional circumstances exist here. Alternatively, Plaintiff may file an amended complaint that does not use a pseudonym for its identity. The required show cause submission or amended complaint must be filed by November 29, 2023. Lastly, pursuant to the District's Local Rules, both attorneys who have appeared on behalf of the plaintiff are directed to either join the general bar of the Northern District of Illinois or file a motion for leave to appear pro hac vice by 11/22/23. Mailed notice

AMENDED complaint by Jin Li against The Partnership and Unincorporated Associations Identified On Schedule A and terminating JANE DOE

Exhibit 1

Exhibit 2

Exhibit Redlined Amended Complaint

(Exhibit Schedule A)

SEALED MOTION by Plaintiff Jin Li

Exhibit 1

Exhibit 2

Exhibit Schedule A

Exhibit Redlined Amended Complaint

Exhibit Redlined Schedule A

(Text of Proposed Order to Seal)

SEALED MOTION by Plaintiff Jin Li for Temporary Restraining Order

Exhibit Brief in Support

(Declaration of Jin Li)

MOTION by Plaintiff Jin Li to seal document SEALED MOTION by Plaintiff Jin Li for Temporary Restraining Order 8

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff is directed to submit its proposed order, including its schedule A, to the Court's proposed order inbox in Word format. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 8 is granted. Plaintiff's motions for leave to file under seal 4 7 9 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 11/29/2023. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion to deposit funds [13] is granted, although the plaintiff does not need leave of court under LR 67.1 to post a bond that was already ordered by the Court. Mailed notice

MOTION by Plaintiff Jin Li for preliminary injunction

MEMORANDUM by Jin Li in support of motion for preliminary injunction 16

Exhibit A

(Declaration of Pete Wolfgram)

CASHIER'S CHECK BOND in the amount of $ 50,000.00 posted by Jin Li

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 16 is taken under advisement. Any objection or response is due before 12/13/23. Upon review of the Certificate of Service, however, the Court directs Plaintiff to supplement the publication of the motion on the website with prominent text advising defendants that: A motion for entry of a preliminary injunction has been filed and that any responses or objections to that motion must be filed before December 13, 2023. The plaintiff must also provide to each defendant the screenshot evidence of the allegedly infringing product(s) offered and sold by that defendant that Plaintiff has provided to the Court in support of its request for a TRO and/or preliminary injunction. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction 16 is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 12/20/23 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4 Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 12/13/2023. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Defendant No. 46, Yanxintech

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 21 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 46 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Defendant No. 11 (Gheinmg)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 23 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 11 is dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Defendants PAIKEWEI DIRECT, MAOHE, and ZEARTEU

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 25 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 22, 26, and 50 are dismissed from this case. The plaintiff is directed to include the defendant identification numbers used in the amended schedule A when referring to defendants in future filings. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to YTONIA (Defendant No. 48), Tzou Store (Defendant No. 36), and LIZHOUMIT-Store (Defendant No. 20)

NOTICE of Voluntary Dismissal by Jin Li as to Defendant No. 24 (Netrud)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 27 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 20, 36, and 48 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Defendant No. 30 (Ruilinnaus)

NOTICE of Voluntary Dismissal by Jin Li as to Defendant No. 25 (OneZero Parts Store)

MAILED patent report to Patent Trademark Office, Alexandria VA.

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.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notices of voluntary dismissal 28 30 31 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 24, 25, and 30 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Ruilinnaus (Defendant No. 30), yxsian69g (Defendant No. 49), Qiudg (Defendant No. 29), Suremi (Defendant No. 33), Elayrine (Defendant No. 8), Wanchiy Official (Defendant No. 38), Pingshopping (Defendant No. 27), and Superior Gallery US (Defendant No. 33)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 35 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 8, 27, 29, 30, 32, 33, 38, 49 are dismissed from this case. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to EBGRF US (Defendant No. 7)

MOTION by Plaintiff Jin Li for default judgment as to

MEMORANDUM by Jin Li in support of motion for default judgment 38

(Declaration Pete Wolfgram)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 37 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendant no. 7 is dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 38 is taken under advisement. Any objections or responses are due by 1/24/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 1/15/24. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order and (2) sending an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them and containing a link to the updated website. Mailed notice

NOTICE of Voluntary Dismissal by Jin Li as to Aijolenlon (Defendant No. 1), Yutinyus (Defendant No. 49), Cinny (Defendant No. 4), Likeets (Defendant No. 19), Yinoua-us (Defendant No. 46), Fchecy-US (Defendant No. 9), JQNus-US (Defendant No. 11) Mseinope-US (Defendant No. 23), qingjunwujD8US-US (Defendant No. 28), Lyingcats (Defendant No. 21) and Daidxours-US (Defendant No. 5)

NOTICE of Voluntary Dismissal by Jin Li as to Liigemi (Defendant No. 17)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notices of voluntary dismissal 42 43 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 1, 4, 5, 9, 11, 17, 19, 21, 23, 28, 46, and 49 are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 38 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 1/25/2024. Mailed notice

FULL SATISFACTION of Judgment as to Yiwushixujunkejiyouxiangongsi (Defendant No. 47)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 47, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 47. Mailed notice

FULL SATISFACTION of Judgment as to Vtosen-Direct (Defendant No. 37)

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 49, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant No. 37.Mailed notice

SATISFACTION of Judgment as to Defendant Brightness-US

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 51, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant Brightness-US. Mailed notice

FULL SATISFACTION of Judgment as to Defendant No. 6

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 53, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 6. Mailed notice

FULL SATISFACTION of Judgment as to Defendant No. 10

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 55, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 10. Mailed notice

LETTER from Yongle Xu. (Received via pro se email on 6/19/24).

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff is directed to file a response to the pro se letter 57 on the docket by 6/28/2024 detailing the efforts it has made to comply with its settlement agreement with the defendant. Mailed notice

RESPONSE by Plaintiff Jin Li to OneZero Part Store's Pro Se Letter Dated June 20, 2024