2024-cv-00523

COMPLAINT filed by Shenzhen Kunshengze Electronic Commerce Co., Ltd.; Filing fee $ 405, receipt number AILNDC-21548843.

Exhibit Exh. 1 - An Infringing Product Listing

Exhibit Exh. 2 - U.S. Pat. No. D980,990 and Copyright Reg. VA 2-343-827

Exhibit Exh. 3 - Intellectual Property Rights Seizure Statistics

Exhibit Exh. 4 - Alibaba, Amazon, and Counterfeiting in the Age of the Internet

Exhibit Exh. 5 - Combating Trafficking in Counterfeit and Pirated Goods

(Exhibit Exh. 6 - U.S. PTO Communication)

SEALED DOCUMENT by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. Sealed Schedule A to Complaint

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. by Konrad Val Sherinian

ATTORNEY Appearance for Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. by Depeng Bi

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. for temporary restraining order

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

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. for leave to file excess pages

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's ex parte motion for TRO 7 is granted. Plaintiff's motions for leave to file under seal 16 and to exceed page limitation 18 are granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 1/24/2024. Mailed notice

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. for extension of time extend TRO

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion to extend the temporary restraining order 22 is granted. Enter order. Mailed notice

EXTENSION of Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 2/1/2024. Mailed notice

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. for preliminary injunction

MEMORANDUM by Shenzhen Kunshengze Electronic Commerce Co., Ltd. in support of motion for preliminary injunction 26

DECLARATION of Konrad Sherinian regarding motion for preliminary injunction 26

(Exhibit Binder of Unreported Decisions)

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), the defendants listed therein are dismissed from this case. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction 26 is taken under advisement. Any objection or response is due before 2/21/24. 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 February 24, 2024. 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

SUMMONS Returned Executed by Shenzhen Kunshengze Electronic Commerce Co., Ltd. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 2/6/2024, answer due 2/27/2024.

(Declaration Declaration of service)

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 32 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 36 and 94 are dismissed from this case. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable John J. Tharp, Jr on 2/21/2024. Mailed notice

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd.discard dkt. no. 41

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion to discard dkt. No. 41 42 is granted. The notice of voluntary dismissal is disregarded. Mailed notice

LETTER from Neal Ali (BitShopUS) dated 2/19/24. (Attachments).

MINUTE entry before the Honorable John J. Tharp, Jr: Defendant BitShopUS has filed a letter requesting assistance from the Court in addressing the claims against it 45. The Court cannot provide litigants with legal advice. Mailed notice

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

MOTION by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. for default judgment as to certain defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notice of voluntary dismissal 47 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 80 and 129 are 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 48 is taken under advisement. Any objections or responses are due by 3/19/24. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 3/11/24. 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

ANSWER to Complaint by smart.brands.shop. (Received by Box.com on 3/9/24).

PRO SE Appearance by Manar Adly. (Received by Box.Com on 3/9/24).

EXHIBIT by Manar Adly. (Received by Box.Com on 3/9/24).

PRO SE Appearance by Manar Adly. (Received from Box.com on 3/11/24) Modified on 3/12/2024.

ANSWER to Complaint by Manar Adly. (Received from Box.com on 3/11/24)

(Exhibits)

MINUTE entry before the Honorable John J. Tharp, Jr: Pro se defendant Manar Adly has filed an exhibit ostensibly depicting communications from an eBay representative that notes, inter alia, "there was no sales or transaction done for the item when it was removed." ECF No. 57. The Court construes this submission as an objection to the pending motion for default judgment. Plaintiff's reply is due by 3/26/24. Mailed notice

REPLY by Plaintiff Shenzhen Kunshengze Electronic Commerce Co., Ltd. to answer to complaint 55, other 57

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for default judgment 50 against the non-objecting defendants is granted. Enter default judgment order. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 3/21/2024. Mailed notice

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

NOTICE of Voluntary Dismissal by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

FULL SATISFACTION of Judgment

MINUTE entry before the Honorable John J. Tharp, Jr: Upon receipt of the plaintiff's notices of voluntary dismissal 65 66 and pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), defendants nos. 31, 32, 65, 66, 81, 83, and 141 are dismissed from this case. The motion for default judgment, to which defendant no. 32 objected 57 58, is denied as to defendant no. 32 as moot in light of the dismissal. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 67, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants No. 101. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr: The plaintiff is directed to file, by 3/28/24, a status report identifying any remaining defendants and their statuses. Mailed notice

STATUS Report No Remaining Defendants by Shenzhen Kunshengze Electronic Commerce Co., Ltd.

MINUTE entry before the Honorable John J. Tharp, Jr:There are no remaining defendants in this matter given the dismissal of the last remaining defendants 68 71. Accordingly, this matter is concluded. All deadlines are stricken, and any pending motions are denied as moot. Civil Case Terminated. The plaintiff may move for a release of bond. Mailed notice

MAILED patent report to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 74, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants Nos. 10 and 90. Mailed notice

FULL SATISFACTION of Judgment

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 76, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendant no. 71. Mailed notice