2024-cv-00849

COMPLAINT filed by OZ Urinal, LLC; Filing fee $ 405, receipt number AILNDC-21588349.

Exhibit 1

(Exhibit 2, 3, and 4 under seal)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff OZ Urinal, LLC by Kevin John Keener

CASE ASSIGNED to the Honorable Steven C. Seeger. Designated as Magistrate Judge the Honorable Heather K. McShain. 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.

MAILED patent report to Patent Trademark Office, Alexandria VA

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by April 30, 2024. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

First AMENDED complaint by OZ Urinal, LLC against THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED IN SCHEDULE A and terminating Does 1-264, As Identified in Exhibit 2

Exhibit 1

(Exhibit 2 and 3 under seal)

SEALED DOCUMENT by Plaintiff OZ Urinal, LLC Schedule A

Exhibit 2 to Complaint

(Exhibit 3 to Complaint)

MOTION by Plaintiff OZ Urinal, LLC for leave to file under seal

MOTION by Plaintiff OZ Urinal, LLC for temporary restraining order temporary injunction, asset restraining order, expedited discovery

MEMORANDUM by OZ Urinal, LLC in support of motion for temporary restraining order 9 temporary injunction, asset restraining order, expedited discovery

DECLARATION of Emre Ozelkan regarding memorandum in support of motion 10

DECLARATION of Kevin Keener regarding memorandum in support of motion 10

(Exhibit 1 and 2 under seal)

SEALED DOCUMENT by Plaintiff OZ Urinal, LLC Exhibit 1 to Declaration of Kevin Keener- part 1 of 4

Exhibit 1 to Declaration of Kevin Keener- part 2 of 4

Exhibit 1 to Declaration of Kevin Keener- part 3 of 4

Exhibit 1 to Declaration of Kevin Keener- part 4 of 4

(Exhibit 2 to Declaration of Kevin Keener)

MOTION by Plaintiff OZ Urinal, LLCElectronic Service of Process

MEMORANDUM by OZ Urinal, LLC in support of motion for miscellaneous relief 14

DECLARATION of Kevin Keener regarding memorandum in support of motion 15

(Exhibit 1 to Declaration of Kevin Keener)

MINUTE entry before the Honorable Steven C. Seeger: Plaintiffs' motion to seal (Dckt. No. 8) is hereby denied, for the reasons stated by this Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

Schedule A to the Complaint by OZ Urinal, LLC

MOTION by Plaintiff OZ Urinal, LLC expedited discovery order

EXHIBIT by Plaintiff OZ Urinal, LLC Exhibit 2 to Complaint regarding amended complaint, 6

(Exhibit 3 to Complaint)

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for electronic service of process under Rule 4(f)(3) (Dckt. No. 14) is hereby granted. Plaintiff's motion for a TRO (Dckt. No. 9) is hereby granted in part. TRO to follow. Plaintiff's motion for an expedited discovery order (Dckt. No. 19) is denied as moot in light of the discovery authorized by the TRO. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Steven C. Seeger on 4/9/2024. Mailed notice.

SURETY BOND in the amount of $ 264,000 posted by OZ Urinal, LLC (Document not scanned).

MOTION by Plaintiff OZ Urinal, LLC for extension of time to Temporary Restraining Order

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion to extend the TRO (Dckt. No. 24) is hereby granted. The Court extends the TRO to May 7, 2024. Mailed notice

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 123 crazyfa90/crazyfa-90; Doe 144 gaspinde0/gaspinde_0; Doe 173 meitalpb; Doe 203 royer8518; Doe 226 usabestdeal

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations identified in Schedule A

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 30 Schubert's rose; Doe 158 jyx861015; Doe 180 morsvid56; Doe 247 excellent.distinct; Doe 251 Geeky_Monkey; Doe 254 Mazey Store; Doe 257 pgrass; Doe 258 Sogoodhappy; Doe 262 wipower

SUMMONS Returned Executed by OZ Urinal, LLC as to The Partnerships and Unincorporated Associations identified in Schedule A on 4/26/2024, answer due 5/17/2024.

MOTION by Plaintiff OZ Urinal, LLC for preliminary injunction

MEMORANDUM by OZ Urinal, LLC in support of motion for preliminary injunction 29

Declaration of Kevin Keener

(Exhibit 1 to Declaration of Kevin Keener- part 3 of 19)

MINUTE entry before the Honorable Steven C. Seeger: At the plaintiff's request, the deadline to file a joint status report is extended to July 31, 2024. Mailed notice.

ATTORNEY Appearance for Defendants QinCool WonderfulStore-US, LJun Wonderful Store, LUO Wonderful Store by Steven G Kalberg

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 6 Go-Deals; Doe 33 T&M Stores; Doe 126 dailydealswarehouse; Doe 189 olaviktoria

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 20 Marsrut TM; Doe 21 One Perfect Home Collection; Doe 31 SHREENIMART; Doe 129 depotus; Doe 188 niuusa; Doe 194 pincha13/pincha-13; Doe 201 replacementaccessories; Doe 202 rosalion; Doe 234 xmasnice

STIPULATION of Dismissal with prejudice of Doe 140 flstanceshop

CERTIFICATE of Service by Kevin John Keener on behalf of OZ Urinal, LLC regarding MOTION by Plaintiff OZ Urinal, LLC for preliminary injunction 29, memorandum in support of motion 30

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 4 DEZHOUWANGTUODIANZISHANGWUYOUXIANGONGSI; Doe 16 LJun Wonderful Store; Doe 19 LUO Wonderful Store; Doe 24 QinCool Wonderful Store-US

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 29 Ruotian pet office store; Doe 140 flstanceshop; Doe 204 rp71497; Doe 216 teklectric

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 39 XMARCHANT; Doe 42 Zeromall; Doe 105 24hoursclickshop; Doe 164 letor8083; Doe 179 morisstore66; Doe 225 uncleyeredmarket/Uncle yered market; Doe 257 pgrass

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 3 CHENGZHI Commercial; Doe 7 Handeming; Doe 139 felixshopping; Doe 171 meesc13; Doe 244 BVBY; Doe 246 excellent.advanced.eu; Doe 247 excellent.distinct

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 25 quality and affodable stores; Doe 34 Teklectric(TM) Kitchen and Home

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 145 happybuybuy; Doe 213 soletgo

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 109 alcheapquality; Doe 131 dorigift; Doe 146 happylifestore2016; Doe 151 immensbrand; Doe 159 kingdomrestore/kingdom_re-store; Doe 163 leogeneralmerchandisestore; Doe 165 lib1847; Doe 172 megamerchandisemart; Doe 175 mixsolution; Doe 178 momandpopwholesale; Doe 183 namahari73; Doe 192 orikari; Doe 196 products-central; Doe 197 pudly123; Doe 200 rconline1; Doe 205 rubystormed; Doe 210 snickersbar1/snickers_bar1; Doe 212 soineed; Doe 214 supermanxbatman; Doe 215 tabooplayground/taboo_playground; Doe 218 theperfectpart; Doe 219 thepositivecarry; Doe 222 topfuture2018; Doe 223 twosticktraders; Doe 230 weepingwillowenterprisesllc; Doe 233 worldwidewebsuppliers; Doe 243 247 Fulfillment; Doe 259 SOLOSHOP3

MINUTE entry before the Honorable Steven C. Seeger: In the last three weeks, Plaintiff has file 10 notices of dismissal or stipulations of dismissal. That's a lot of docket clutter. Going forward, Plaintiff may not file more than one notice of dismissal per week. That prohibition does not apply to a notice of dismissal that ends the case. On that note, Plaintiff must file a status report by May 24, 2024, and must address how many defendants are left (by name), and where things stand. Responses to the complaint were due by May 17, 2024. (Dckt. No. 28) Mailed notice

MOTION by Plaintiff OZ Urinal, LLC for default judgment as to remaining defendants

MEMORANDUM by OZ Urinal, LLC in support of motion for default judgment 45

Declaration of Kevin Keener

Exhibit 1 to Declaration of Kevin Keener- part 3 of 19

(Exhibit 2 to Declaration of Kevin Keener)

CERTIFICATE of Service by Plaintiff OZ Urinal, LLC regarding MOTION by Plaintiff OZ Urinal, LLC for default judgment as to remaining defendants 45, memorandum in support of motion, 46

STATUS Report by OZ Urinal, LLC

ATTORNEY Appearance for Defendants KkaFFe, Leetye Mei by He Cheng

MOTION by Defendants KkaFFe, Leetye Mei for extension of time to file answer or otherwise respond to Plaintiff's Complaint

NOTICE of Motion by He Cheng for presentment of motion for extension of time to file answer 50 before Honorable Steven C. Seeger on 5/28/2024 at 09:30 AM.

MINUTE entry before the Honorable Steven C. Seeger: The unopposed motion for extension of time to answer or otherwise respond to plaintiff's complaint (Dckt. No. 50) is granted. Defendants KkaFFe and Leetye Mei shall respond to plaintiff's complaint by June 7, 2024. The motion hearing set for May 28, 2024 is hereby vacated. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the motion for default judgment (Dckt. No. 45). Defendants must respond by June 7, 2024. This obligation does not apply to Defendant KkaFFe and Leetye Mei, who received an extension. The Court directs Plaintiff to have meaningful settlement discussions with all remaining defendants. The parties must discuss settlement in good faith and with a sense of purpose. A joint status report about settlement is due by June 6, 2024. Mailed notice

MOTION by Defendants KkaFFe, Leetye Mei to unseal document sealed document, 13

MOTION to Lift Asset Restraining Order by KkaFFe, Leetye Mei

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 132 elarashop/Elara Shop; Doe 149 idansabag; Doe 152 inbalstoreus; Doe 153 innovatistore21; Doe 168 mahus-31; Doe 180 morsvid56; Doe 186 ningning373; Doe 236 yanivmarys

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 11 KkaFFE; Doe 13 Leetye Mei

Motion to Release Accounts and Reinstate Product Listings by KkaFFe, Leetye Mei

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's response to the motion to unseal (Dckt. No. 54) and the motion for release of account and to reinstate product listings (Dckt. No. 58) is due by July 12, 2024. Mailed notice

NOTICE of Voluntary Dismissal by OZ Urinal, LLC with prejudice of Doe 26 Qurly; Doe 37 wowhouse-us; Doe 116 bohemingo; Doe 195 primeac-usa

RESPONSE by Plaintiff OZ Urinal, LLC to other 58

Declaration of Kevin Keener

Exhibit 1

Exhibit 2

(Exhibit 3)

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's response to the motion to release accounts. The issue is moot. The motion (Dckt. No. 58) is denied as moot. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion to convert the TRO into a preliminary injunction (Dckt. No. 29) is hereby granted. Based on the record, the Court hereby finds that Plaintiff has satisfied all of the requirements for a preliminary injunction under Rule 65(a). This order excludes any defendant who has been dismissed from the case. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Defendants KkaFFe and Leetye Mei filed a motion to unseal documents (Dckt. No. 54). Defendants KkaFFe and Leetye Mei were voluntarily dismissed from the case on June 4, 2024 (after they filed their motion). See Notice of Voluntary Dismissal (Dckt. No. 57). So, the motion to unseal documents is denied as moot. Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for the entry of default and default judgment against the remaining defendants (Dckt. No. 45). The deadline to respond to the complaint has come and gone. The response to the complaint is late. The Court hereby enters default against Defendants under Rule 55(a). The response is due by July 30, 2024. A failure to respond will lead to appropriate relief, including granting the motion and entering final judgment. Mailed notice

NOTICE of Voluntary Dismissal by OZ Urinal, LLC without prejudice of Doe 10 JKMTR; Doe 41 Yuyong Department Store-us

MINUTE entry before the Honorable Steven C. Seeger: On July 16, 2024, this Court entered an order requiring the remaining defendants (who have not been voluntarily dismissed) to respond to the motion for default judgment by July 30, 2024. See 7/16/24 Order (Dckt. No. 65). That deadline has come and gone, and Defendants filed nothing. The motion for default judgment (Dckt. No. 45) is hereby granted in part. Final Judgment Order to follow. The case is closed. Civil case terminated. Mailed notice.

PERMANENT INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 7/31/2024. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Steven C. Seeger on 7/31/2024. Mailed notice.

MAILED patent closing report with certified copies of orders dated 7/31/2024 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding entered judgment, order 69 as to Doe 9 HealthSTEC; Doe 261 welcome to happy life

FULL SATISFACTION of Judgment regarding permanent injunction, order 68, entered judgment, order 69 as to Doe 2 Bybest

FULL SATISFACTION of Judgment regarding entered judgment, order 69 as to Doe 108 addone2536