2024-cv-01447

COMPLAINT filed by Koninklijke Philips N.V.; Filing fee $ 405, receipt number AILNDC-21660253.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff Koninklijke Philips N.V. Schedule A regarding complaint 1 Modified on 3/26/2024.

MOTION by Plaintiff Koninklijke Philips N.V. for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Koninklijke Philips N.V.

Notice of Claims involving Trademarks by Koninklijke Philips N.V.

ATTORNEY Appearance for Plaintiff Koninklijke Philips N.V. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Koninklijke Philips N.V. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Koninklijke Philips N.V. by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Koninklijke Philips N.V. by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Sunil R. Harjani. Case assignment: Random assignment. (Civil Category Two).

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 trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff Koninklijke Philips N.V. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Koninklijke Philips N.V. 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 Jan de Visser regarding memorandum in support of motion 14

(Exhibit 1)

DECLARATION of Jan de Visser by Plaintiff Koninklijke Philips N.V. Exhibit 2 - Parts 1-8 regarding declaration 16 Modified on 3/26/2024.

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

(Exhibit 2-8)

MOTION by Plaintiff Koninklijke Philips N.V. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Koninklijke Philips N.V. in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are set for a telephonic motion hearing on 3/7/2024 at 10:00 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 3/7/2024. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 3, ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 13, and motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 18 are granted. Enter Sealed Temporary Restraining Order. The Clerk's Office 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 2 - Parts 1-8 17. The Temporary Restraining Order shall be maintained under seal until further order of the Court. The Temporary Restraining Order is entered effective 10:00 a.m. on 3/7/2024 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. Telephonic status hearing set for 3/21/2024 at 10:15 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

TEMPORARY Restraining Order: Signed by the Honorable Andrea R. Wood on 3/7/2024. Modified on 3/26/2024.

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

INJUNCTION BOND in the amount of $ 10,000.00 posted by Koninklijke Philips N.V. (Document not scanned). (Received at the Intake Counter on 3/12/24).

MOTION by Plaintiff Koninklijke Philips N.V. for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Koninklijke Philips N.V. in support of motion for preliminary injunction 25

Declaration of Kahlia R. Halpern

(Exhibit 1)

SUMMONS Returned Executed by Koninklijke Philips N.V. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/18/2024, answer due 4/8/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

ATTORNEY Appearance for Plaintiff Koninklijke Philips N.V. by Marcella Deshonda Slay

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 3/21/2024. Only Plaintiff appeared. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction as to certain defendants 25 is granted. Enter Preliminary Injunction Order. The Temporary Restraining Order expires on its own terms as to Defendant nos. 1-10. Plaintiff's counsel shall provide a copy of this order to the platforms for those ten Defendants that are not covered by the preliminary injunction to inform them that the Temporary Restraining Order is no longer in effect as to those ten Defendants. The Clerk's Office is directed to unseal: (1) Schedule A to the complaint 2, (2) Exhibit 2 - Parts 1-8 17, and (3) the sealed temporary restraining order 23. Plaintiff's 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 5/1/2024 at 10:00 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 3/21/2024. Mailed notice

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NOTICE of Voluntary Dismissal by Koninklijke Philips N.V. as to certain defendant

NOTICE of Voluntary Dismissal by Koninklijke Philips N.V. as to certain defendant

NOTICE of Voluntary Dismissal by Koninklijke Philips N.V. as to certain defendant

NOTICE of Voluntary Dismissal by Koninklijke Philips N.V. as to certain defendants

SUMMONS Returned Executed by Koninklijke Philips N.V. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/12/2024, answer due 5/3/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 5/1/2024 and continued to 5/16/2024 at 10:00 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

MOTION by Plaintiff Koninklijke Philips N.V. for entry of default, MOTION by Plaintiff Koninklijke Philips N.V. for default judgment as to all Defendants with the exception of a certain Defendant

(Exhibit A)

MEMORANDUM by Koninklijke Philips N.V. in support of motion for entry of default, motion for default judgment, 37

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 38

(Exhibit 1)

MOTION by Plaintiff Koninklijke Philips N.V. to approve consent judgment as to a Certain Defendant

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of Defendant no. 37 37 will be heard at the telephonic hearing set for 5/16/2024 at 10:00 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 5/16/2024. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment against the Defendants identified on Schedule A, with the exception of Defendant no. 37 37 and agreed motion for entry of a consent judgment as to Defendant no. 37 40 are taken under advisement. Telephonic status hearing set for 6/13/2024 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

NOTICE of Voluntary Dismissal by Koninklijke Philips N.V. as to certain defendant

ATTORNEY Appearance for Defendant HOME LIFE Co.ltd by Adam Edward Urbanczyk

MOTION by Plaintiff Koninklijke Philips N.V. to approve consent judgment Supplemental (Agreed)

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 6/13/2024. As discussed on the record, by 6/20/2024, Plaintiff shall obtain a written consent or otherwise make a supplemental filing evidencing Defendant's consent to the entry of the proposed consent judgment 40. Telephonic status hearing set for 7/2/2024 at 10:00 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

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing set for 7/2/2024 is stricken and reset for 7/11/2024 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

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's agreed motion for entry of a consent judgment as to Defendant No. 37 40, as supplemented 45 is granted. Plaintiff's motion for entry of default and default judgment 37 is granted. Enter Default Judgment. All other pending motions and hearing dates are stricken. Civil case terminated. Mailed notice

MOTION by Plaintiff Koninklijke Philips N.V. for Entry of Signed Order

(Exhibit A)

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of signed order [49] is granted. Enter Order. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 8/25/2025. Mailed notice