2024-cv-00197

COMPLAINT filed by Svenja Schmitt; Filing fee $ 405, receipt number AILNDC-21499105.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Svenja Schmitt Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Yanling Jiang

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Yi Bu

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Adam Grodman

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Christopher Romero

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 3).

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 Svenja Schmitt for leave to file under seal

MOTION by Plaintiff Svenja Schmitt for leave to file excess pages

MEMORANDUM in support of 13 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Svenja Schmitt

(Exhibit 1, of Svenja Schmitt's declaration)

SEALED EXHIBIT by Plaintiff Svenja Schmitt Sealed Exhibit 2, Declaration of Svenja Schmitt regarding memorandum in support of motion, 14

Exhibit 2-1

(Exhibit 2-2)

MAILED Copyright report to Registrar, Washington DC.

EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Lindsay C. Jenkins for all further proceedings pursuant to Local Rule 28:294(b). Honorable Joan H. Lefkow no longer assigned to the case. Signed by Executive Committee on 1/9/24.

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

SURETY BOND in the amount of $ 10,000 posted by Svenja Schmitt. (Document not imaged)

MOTION by Plaintiff Svenja Schmitt for preliminary injunction

MEMORANDUM by Svenja Schmitt in support of motion for preliminary injunction 21

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

SUMMONS Returned Executed by Svenja Schmitt as to The Partnerships and Unincorporated Associations Identified on Schedule A on 1/19/2024, answer due 2/9/2024.

(Declaration of Service)

ATTORNEY Appearance for Plaintiff RIZTECHNOLOGY LLC by Ruoting Men

MOTION by Attorney Ruoting Men to withdraw as attorney for RIZTECHNOLOGY LLC. New address information: 2108 N ST STE N SACRAMENTO, CA 95816

MINUTE entry before the Honorable Lindsay C. Jenkins: Attorney Ruoting Men's motion to withdraw 25 is granted. Attorney Ruoting Men no longer assigned to this case. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 21 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 January 25, 2024." 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.

CERTIFICATE of Service by Plaintiff Svenja Schmitt regarding order on motion for preliminary injunction, text entry, set motion and R&R deadlines/hearings, 27

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 21 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 28 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm Jiangip 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 1/26/2024. Mailed notice.

NEW PARTIES: HEZHONGKUI, CXYbhuo, GuoYuKe shop, gaoxiaodian, shanxiKaiFeiMaoYi, Vedolay, LIANZHONG1, Zhang hai tao, Claral, Kaliks Shop, huluwamaoyi, Duskmall Free & Fast Shipping, LavetoniA, QUAROS, Bopcus, INTEROOKIE US, ONCEX, Genta Kojima, PetanizeGifts, VIKTERM, HANGA, SLEEP EASLY, TNN SMARTSOLUX, KIAN-LLC, NOPAN-LLC, H.Y.Shopp, Haler, zhuosenyu, WXM ShopUS, XLin Tech, Shenzhen HongHeFu Household Products Co. Ltd., Edauto., Blllue US, VODEFOX-us, Tedaekti Direct, DMX, TiHu, FAVORGEAR, HiCASE Pro, Shuyi Sp shop, shenzhenshi zhaodianxiuxi maoyi youxian gongsi, QYH-US, vsllcau., BQBQOER, NailKING, WishColorful, qinmeixiao and Zenladen LLC USA added to case caption.

NEW PARTIES: SHENGYIYI, Dsgc, JOKIVTOU, LIUGANGOO, Coler Of Life, LuoBinBHD, Briyhose, AMZ-ZXX, SENSEN Decor Art, SPESHION, HOANGSONST, Zayvor, Visit Fystarrky's Store, LinXianReDianBanGongYongPinJingXiaoDia n, daizhilu122, Vesna, Giodo Store, Odile Store, QualitySStore, Easyoyo, BYBYCD, DIGNATURE, YCDGJMY and milkywhite added to case caption.

NEW PARTIES: blakberry, Riches, Better Funiture Co. Ltd., luosa, maggreat, twklestars, fashionstyle, queenly, Cheers, wishlistbester, Dealovy Co.Ltd, onfine Co. ltd, vovofine Co., LTD, TXFQZL, HeZeFengGangWang, VASYL Flagship store, EJWQWQE, Heshuo Trading Inc, Zeiyignr, Yomiee HOME&OUTDOORS, YYNKM, Sulgyt, Daiosportswear, Mouliraty and SHENGXINY added to case caption.

NEW PARTIES: SHENGXINY, digtalshack, SGCYLOWQ INC, lai rong Trading Co., Ltd., Nanchang Changke Electronic Technology Co., Ltd., Kingyoungall, Cethrio, Tejiojio, baskuwish, POROPL, Beauty Home, Ecqkame Co. ltd, DAETIROS, KMSXM Trading Co. Ltd, Qonioi, HOMBOM, Brilliant, CLESALE Online Store, Meitianfacai, Gallickan, Dezsed, IELSKGS Clothing Shop, Honeeladyy, Amtdh, Turilly, DECILRO Clothing Shop and EQWLJWE added to case caption.

NEW PARTIES: HAOTAGS, qolati, MaTPR, Fesfesfes, Fumantang, JenniferLiz, XEOVHVLJ, Tiitstoy, Mittory Company, Wovilon, RnemiTe-amo, lulshou, Wiueurtly, soon, AIYUQ.U INC, QIAN GONG, WENY Store, Yuelianxi, NKOOGH Clothing, BOTE LLC, MMolecule, Ynmk Jun, NEGJ, Enco, ASEIDFNSA Clothing, B Joy, ForestYashe Fashion Co.,Ltd, Beppter Learning, chancheng Co.Ltd, Adviicd Chioce, WANYNG INC, Trayknick, glaryyears and porfeet added to case caption.

NEW PARTIES: Yazhiji, Luckymimi, oudi co.,ltd, DiManFeng Inc, Airpow, Ultra-fast delivery, CokTak, Me LLC, Sunhillsgrace.Co. Ltd, sichuanchengwang, Fastest Shipping, Dibo Trading Co.Ltd, JPS Blossoms, Happy City Co.Ltd, HuaShao LLC and Dowell Network added to case caption.

NEW PARTIES: Defendant 1, Defendant 32 and Defendant 66 added to case caption.

ATTORNEY Appearance for Defendants onfine Co. ltd, wishlistbester by Michael Thomas Stanley

MOTION by Defendants onfine Co. ltd, wishlistbester for extension of time to file answer regarding complaint 1 Unopposed Motion for Extension of Time to Answer Complaint

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant 85 wishlistbester and 87 onfine Co. Ltd's unopposed motion for extension of time to respond 32 is granted. These Defendants' responsive pleadings are due by March 1, 2024. Mailed notice.

ATTORNEY Appearance for Defendants Adviicd Chioce, B Joy, Cheers, Dibo Trading Co.Ltd, Enco, JenniferLiz, Luckymimi, Trayknick, Ynmk Jun, porfeet by Adam Edward Urbanczyk

MOTION by Defendants Adviicd Chioce, B Joy, Cheers, Dibo Trading Co.Ltd, Enco, JenniferLiz, Luckymimi, Trayknick, Ynmk Jun, porfeet for extension of time UNOPPOSED

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants Adviicd Chioce, B Joy, Cheers, Dibo Trading Co.Ltd, Enco, JenniferLiz, Luckymimi, Trayknick, Ynmk Jun, porfeet's unopposed motion for extension of time [35] to answer is granted. These Defendants' responsive pleading is due by March 18, 2024. Mailed notice.

MOTION by Plaintiff Svenja Schmitt for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Svenja Schmitt in support of motion for default judgment[37]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

ATTORNEY Appearance for Defendant HeZeFengGangWang by Michael Thomas Stanley

MOTION by Defendant HeZeFengGangWang for extension of time to file answer regarding complaint[1] Unopposed Motion for Extension of Time to Answer Complaint

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendants HeZeFengGangWang, Adviicd Chioce, B Joy, Cheers, Dibo Trading Co.Ltd, Enco, JenniferLiz, Luckymimi, Trayknick, Ynmk Jun, porfeet. Before the Court is Plaintiff's motion [37] for entry of default and default judgment against certain remaining Defendants. All remaining defendants 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 February 26, 2024. 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.

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant HeZeFengGangWang's unopposed motion for extension of time [40] is granted. Defendant HeZeFengGangWang's responsive pleading is due by March 11, 2024. Mailed notice.

CERTIFICATE of Service by Plaintiff Svenja Schmitt regarding order on motion for default judgment, text entry, [41]

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff is directed to submit a proposed default judgment order as to the relevant defendants to the Court's proposed order box by February 28, 2024. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following Order does not apply to Defendants wishlistbester and JenniferLiz. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [37] 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 the remaining Defendants (Plaintiff has failed to seek an accounting of profits), the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $50,000 is an appropriate award of statutory damages. Enter Partial Final Judgment Order. Mailed notice.

PARTIAL DEFAULT JUDGMENT ORDER Signed by the Honorable Lindsay C. Jenkins on 2/27/2024. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 131 Fumantang and no. 85 wishlistbester

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant onfine Co. Ltd's (no. 87) responsive pleading was due by March 1, 2024 [33] but nothing was filed, and Plaintiff has not filed a notice of dismissal. The parties are to file a short status report as to the status of this Defendant by March 8, 2024. Mailed notice.

MOTION by Defendants HeZeFengGangWang, onfine Co. ltd for extension of time to file answer regarding complaint[1] Unopposed Motion for Extension of Time to Answer Complaint

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants onfine Co. ltd and HeZeFengGangWan's unopposed motion for an extension of time [50] is granted. Defendants' responsive pleading is now due by March 26, 2024. Mailed notice.

STATUS Report Joint Status Report Pursuant to [49] by Svenja Schmitt

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court granted several Defendants an extension on the deadline to answer Plaintiff's Complaint until March 18, 2024. [36] Plaintiff voluntarily dismissed claims against all but one of those Defendants, JenniferLiz. [44] Assuming Plaintiff has not already resolved claims against JenniferLiz, the Court extends the deadline to answer until March 26, 2024. By March 27, 2024, the parties are to file a short status report as to each party against which claims remain pending or, if none, stating whether this case can be terminated. Mailed notice.

MOTION by Plaintiff Svenja Schmitt to approve consent judgment

MOTION by Plaintiff Svenja Schmitt to approve consent judgment [Corrected]

MINUTE entry before the Honorable Lindsay C. Jenkins:Plaintiff's motion for approval of a consent judgment [54][55] is granted. Separate Order to issue. Plaintiff's March 27, 2024 status report [53] remain due tomorrow. Mailed notice.

CONSENT JUDGMENT ENTERED as to Defendant No. 132 (JenniferLiz) Signed by the Honorable Lindsay C. Jenkins on 3/26/2024. Mailed notice.

STIPULATION of Dismissal as to Defendant Nos. 87 onfine Co. ltd and 90 HeZeFengGangWang

MINUTE entry before the Honorable Lindsay C. Jenkins:The parties' have filed a joint stipulation of dismissal [58], the terms of which are set forth therein. Civil case closed. Mailed notice.

SATISFACTION of Judgment as to [Certain] defendants

SATISFACTION of Judgment as to Defendant no. 91 VASYL Flagship store

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 70 QualitySStore

ATTORNEY Appearance for Respondents Shenzhen Laibo Technology Co, Ltd (d/b/a LAlBO US), Dongguan Guangliying Electronic Technology Co, Ltd. (d/b/a KEFEYA US OFFICIAL), Shenzhen Jiashi Technology Co., Ltd. (d/b/a gyflp), Shenzhen Pengling Intelligent Technology Co., Ltd. (d/b/a FICIHP), Shenzhen Lianshengtuo Technology Co., Ltd. (d/b/a ALLVIA), Qingyuanshi Maigi Intelligent Technology Co., Ltd. (d/b/a APILDELLA), Shenzhen Weidong Zhi Xin Technology Co, Ltd. (d/b/a WESTHOD US), Shenzhen Donghongze Trading Co., Ltd. (d/b/a CIDETTY Electronics), Shenzhen Jiacaili Technology Co, Ltd. (d/b/a KasoreyUs), Shenzhen Keangsi Trade Co. ltd. (d/b/a AetherSpark), Shenzhen Huibaijia Technology Co, Ltd. (d/b/a Venraty), Triple A International Trading Inc. (d/b/a US-Alecewey), Rongbang Enterprise USA INC (d/b/a BQAA US store), R&T BROTHERS LLC (d/b/a CopGain Store-us), FUCANG ENTERPRISES USA INC (d/b/a ppL Technology Supply), Bohua HUAGAOLI Electronic Technology Co, Ltd. (d/b/a VargaoliDeal), RIZTECHNOLOGY LLC (d/b/a JJTechGiant), Shenzhen Mingsirui Technology Co, Ltd. (d/b/a SMISEACOW US), LIVING SKYLIGHT Inc. (d/b/a WallyDeals), Shenzhen SHANGJIAMEIPIN E-Commerce Co, Ltd. (d/b/a Kwumsy), Shenzhen City Free Vast Science and Technology Co., Ltd (d/b/a Maxfree) by Ruoting Men

SATISFACTION of Judgment as to Defendant no. 132 JenniferLiz and no. 163 oudi co.,ltd