2024-cv-02714

COMPLAINT filed by Levi Strauss & Co.; Filing fee $ 405, receipt number AILNDC-21820583.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Levi Strauss & Co. Schedule A regarding complaint[1]

MOTION by Plaintiff Levi Strauss & Co. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Levi Strauss & Co.

Notice of Claims Involving Trademarks by Levi Strauss & Co.

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Rachel S Miller

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Quinn Bradley Guillermo

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2).

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 Robert W. Gettleman: Plaintiff's Motion For Leave To File Under Seal 3 is granted. Emailed notice

MOTION by Plaintiff Levi Strauss & Co. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Levi Strauss & Co. in support of motion for temporary restraining order[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Zachary Toczynski regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Levi Strauss & Co. Exhibit 2 Parts 1-7 regarding declaration[15]

MOTION by Plaintiff Levi Strauss & Co. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Levi Strauss & Co. in support of motion for miscellaneous relief[17]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[18]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic motion hearing on Plaintiff's Ex Parte Motion For Entry Of A Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, And Expedited Discovery [12] and Motion For Electronic Service Of Process Pursuant To Fed. R. Civ. P. 4(f)(3) [17] set for 4/11/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing on ex parte motions held on 4/11/2024. For the reasons stated on the record, Plaintiff's Ex Parte Motion For Entry Of A Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, And Expedited Discovery [12] and Motion For Electronic Service Of Process Pursuant To Fed. R. Civ. P. 4(f)(3) [17] are granted. Enter sealed order. Telephonic hearing set for 4/25/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 4/11/2024. Emailed notice

Registry Deposit Information Form by Levi Strauss & Co.

SURETY BOND in the amount of $ 10,000 posted by Levi Strauss & Co. (Document not scanned.)

TRANSCRIPT OF PROCEEDINGS held on April 11, 2024 before the Honorable Robert W. Gettleman. Order Number: 48482. Court Reporter Contact Information: Nancy L. Bistany nancy_bistany@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 5/9/2024. Redacted Transcript Deadline set for 5/20/2024. Release of Transcript Restriction set for 7/17/2024.

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Marcella Deshonda Slay

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

MOTION by Plaintiff Levi Strauss & Co. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Levi Strauss & Co. in support of motion for preliminary injunction[27]

Declaration of Marcella D. Slay

Exhibit 1

SUMMONS Returned Executed by Levi Strauss & Co. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/22/2024, answer due 5/13/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic motion hearing held on 4/25/2024. No defendants appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of A Preliminary Injunction As To Defendant Nos. 4-107 27 is granted. Enter order. Telephonic hearing set for 6/6/2024 at 9:15 a.m. Plaintiff is directed to file a brief status report by 5/30/2024. The law firm of Greer Burns & Crain Ltd. is ordered to add the Defendants' names included in this motion to the docket within three business days. The Clerk is directed to unseal Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Zachary Toczynski 16 and the TRO 22. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 4/25/2024. Emailed notice

NEW PARTIES: Dongguan Qishi Chenya Design Service Group, Hangzhou Fashion Oxygen Trade Co., Limited, Shenzhen ZFK Trade Co., Ltd., JanJean, Kvysinly, SWISEO, blueberry11, chenweiqin1, chenweiqin10, chenweiqin12, chenweiqin2, chenweiqin6, chenweiqin9, chhipluxury06, chicinteriors, clothing112, clothing192, clothing201, daffodyd, designer22, designerclothes2024, designerclothing9505, dhgat1, dhgat10, dhgate811, dhgateanqel, dhgatechrome, dhgatecuba, dhgatemax, dhgatemoney, dhgatequan, dhgatesale6, dhgatessr, dhgatesvip1, dhgatevx, dhgateyoung, dhjllsjin, dhwdeccvd, dhwjinlu, dhwlklkwz, dhwloijh, dhwloiljh, dhwuuywsa, dsaz4, elssclothes05, fashionclothing16, fashionstoresss8648, fengi21, gallerydepthoodie, good_clothing_nice, haojestasn1, hbl0006, highgrade11, highgrade12, highgrade13, highgrade15, hjc007, hjc008, hjc009, huangdh13, huangdh14, huangdh15, huangdh24, huangdh25, huangdh27, huangdh28, huangdh29, huangdh30, hyl01, hyl02, Idstyleclothes, jacket88, jeans88, liuying022, liuying11, liuying33, luxury_shop5, lz_clothe_top1, monclair_jacket01, newageclothing9504, offvai, perfectvalue116, perfectvalue224, perfectvalue82, perfectvalue83, popular_store1, purple_666, purple_gh, sunflower_lwl, top_nice_shop, vipsalemax8, wjh09, wqr1506, xgx_sunflower, xinshuo22, xinshuo25, xinshuo31, xinshuo42, xurx11, yogalulu888, happytrade518, mazhouwei2, Bi Er Fan Brand Shop, chengfengjiao, Cow doll childrens clothing, Midian Childrens wear and Tilya Clothing added to case caption.

NOTICE of Voluntary Dismissal by Levi Strauss & Co. as to certain defendant

SUMMONS Returned Executed by Levi Strauss & Co. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/13/2024, answer due 6/3/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

STATUS Report pursuant to 30 by Levi Strauss & Co.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 6/6/2024. No defendant appeared on the hearing. Telephonic hearing set for 6/25/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. 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. Emailed notice

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Thomas Joseph Juettner

MOTION by Plaintiff Levi Strauss & Co. for entry of default, MOTION by Plaintiff Levi Strauss & Co. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Levi Strauss & Co. 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)

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 6/25/2024. No defendants appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion for Entry of Default and Default Judgment [37] is granted. Enter order. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 6/25/2024. Emailed notice

FULL SATISFACTION of Judgment regarding order[41] as to certain defendants

MAILED Closing Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Order dated 6/25/2024)

NOTICE of withdrawal of bond 24 by Justin R. Gaudio from Greer Burns & Crain Ltd. (Received at the Intake Counter on 7/24/2024)

ATTORNEY Appearance for Defendants JanJean, Kvysinly by Michael James Hopkins

MOTION by Defendants JanJean, Kvysinly to vacate order 41

MEMORANDUM by JanJean, Kvysinly in support of motion to vacate 46

Declaration A-Declaration of Lei Anqu

Exhibit A-1-Amazon Notification Emails

Exhibit A-2-Service Emails

Exhibit A-3-Settlement Emails

Exhibit A-4-EFE Product Listings

Exhibit A-5-Images of EFE Products

(Exhibit B-Product Comparisons)

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Lucas Allen Peterson

MINUTE entry before the Honorable Robert W. Gettleman: The court sets the following briefing schedule on Defendants Janjean and Kvysinly's Motion to Vacate Default Judgment Order Pursuant to Rules 55(c) & 60(b) 46 : plaintiff's response due 8/22/2024; defendant's reply due 9/5/2024. Enforcement of the default judgment 41 entered against Defendants Janjean and Kvysinly is stayed pending the court's ruling on the motion to vacate. Emailed notice

ATTORNEY Appearance for Plaintiff Levi Strauss & Co. by Berel Yonathan Lakovitsky

STIPULATION of Dismissal as to certain Defendants (Joint)

MINUTE entry before the Honorable Robert W. Gettleman: In light of the Joint Stipulation to dismiss all claims against Defendant JanJean and Kvysinly 51 entered on 8/15/2024, defendants' JanJean and Kvysinly's Motion to Vacate 46 is terminated as moot. Emailed notice

FULL SATISFACTION of Judgment regarding order 41 as to certain defendant