2024-cv-03727

COMPLAINT filed by Converse Inc.; Filing fee $ 405, receipt number AILNDC-21941045.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Converse Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Converse Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Converse Inc.

Notice of Claims Involving Trademarks by Converse Inc.

ATTORNEY Appearance for Plaintiff Converse Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Converse Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Converse Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Converse Inc. by Berel Yonathan Lakovitsky

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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 Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Converse Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Converse Inc. in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Joe Pallett regarding memorandum in support of motion[15]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 3 - Parts 1-10 regarding declaration[17]

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 3 - Part 11 regarding declaration[17]

MOTION by Plaintiff Converse Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Converse Inc. in support of motion for miscellaneous relief[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte telephone conference held on 5/10/2024. Transcript is to remain sealed. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [14] is granted. Plaintiff's motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [20] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 5/10/2024. Mailed notice.

CIVIL BOND in the amount of $ 120,000 posted by Converse Inc. (Document Not Imaged).

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

MOTION by Plaintiff Converse Inc. for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Converse Inc. in support of motion for preliminary injunction 26

Declaration of Marcella D. Slay

(Exhibit 1)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 26 is set for 5/24/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

SUMMONS Returned Executed by Converse Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/20/2024, answer due 6/10/2024.

Declaration of Berel Y. Lakovitsky

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 5/24/2024. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [26] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibit 3 to the Declaration of Joe Pallett [18-19], and the TRO [24]. Plaintiff's counsel is ordered to add ALL Defendant names listed in 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. A telephone status hearing is set for 6/25/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin on 5/24/2024. Mailed notice.

NEW PARTIES: CNACC (Shanghai) Import & Export Co., Ltd., Dongguan Huamei Impression Ecommerce Co., Ltd., King Ten Digital Limited, Nanjing Kaifeng Trading Co., Ltd., Ningbo Yuejia Trading Co., Ltd., Ruian Kaiyibu Trade Co., Ltd., Union Chance Co., Ltd., Wochuan (shandong) International Trade Co., Ltd., Yiwu Chaomeng Jewelry Co., Ltd., Yiwu Like Clothing Co., Ltd., BTMOTTZ Official Store, JKPUDUN Official Store, OKDILIER Store, Shop4478130 Store, A1ADLGZ0HZZIEU, A1L1NGF6JRK849, A2N9GQ6M1I82DQ, A32GMRUNY61A2F, A3C0YUMCFK3YBC, A3EU5CEAZ3N36X, APODTY, AWI7NI0UH46G1, bailishangmaoyouxiangongsi, biaterd-US, Bijuzic-US, BoBinYu, Ceavo, changchunshixinshengbinshangmaoyouxiangongsi, chenyingstore, Ciciglow, CongJie, Cy-Trendy US Brand, DaiFan, DaiLiyuQMHGDNJHGUNJFYT, dongshangjiapin, ElectronJY, FANG(7-14 days delivery), Folanda-US, foshanshichaoxushuojixieshebeizulinyouxiangongsi, Furnoore, Fuyuestor, GJDZSWYXGS, Goolily, guangjianshangmaoyouxiangongsi, GUOZICHENLIJING, gzdwkj, HuangXianGuoChengDuGuanHuiOuChuangKeJiYouXianGongS, huidongbomu, Ironctic, JingBoB, jinshiyaju, JXXSHANGGUAN, kekelongshangmao, lshell, LULU SPORTY & FASHION, Lysarhy, Magwen226, Mysterious Life Store, Nancong, Nanyangshiwanchengqubaiyouhong, nanyangshiwanchengquxuwenbaihuolingshoudian, nanyangxingzhejiancaiyouxiangongsi, Obtaom shoes, Pippen Store, Please stay young and beautiful all the time, Seyoys, Shanborte, shanglidianzi, Siuyinzae-US, SluttShawtyeP, SMS2020, Starmoon1116, Sunport-Z, SZJCKJJSYXGS, tangjunbin, Tideters, Tommy1, Tomoerds, Tong Ting Official Store, WaNana, XIAOYAHUI, Xingtu Trading Company, xinxinxiaowu, Xiuganpo-US, Yasashi11, Yetaland Direct, yidayoupin, yongchunshangguistore, yuehonghohs, yungejianzhu, Zenxiue-US, ZhangChi Department Stores, fenghou19834190, ggdbs, gleewofa, jewelryshop6, lolita_shoe, officeo, sneaker0524, tnshoes_shop9, top_brands, diuxue60, dong4643, duckqueens, eva_dollhouse, FJNIOWRNFGUIEWN, internationaldiaryA, jhhjkh_kong, mybeautyshop2014, wallpointo, wedgwooay, yyuc2c, hanggaoda trading, Honkakufen, justhard, S SERENABLE, Yilangjiashangmao, zhengzhenghao, zuguohuaduo and y-s j u s a added to case caption.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

SUMMONS Returned Executed by Converse Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/3/2024, answer due 6/24/2024.

Declaration of Berel Y. Lakovitsky

Exhibit A

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

ATTORNEY Appearance for Defendants Bijuzic-US, Ceavo, Ciciglow, Folanda-US, Furnoore, Goolily, Ironctic, Lysarhy, Magwen226, Nancong, Seyoys, Shanborte, Xiuganpo-US, Yasashi11, Zenxiue-US, biaterd-US, xinxinxiaowu by Timothy Tiewei Wang

Exhibit A - List of Represented defendants

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

ATTORNEY Appearance for Defendants Yilangjiashangmao, hanggaoda trading, zhengzhenghao, zuguohuaduo by Huicheng Zhou

MOTION by Defendants Yilangjiashangmao, hanggaoda trading, zhengzhenghao, zuguohuaduo for extension of time

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed Motion for extension of time [39] is granted. Defendants Hanggaoda trading, Zhengzhenghao, Zuguohuaduo and Yilangjiashangmao are to respond to the complaint by 07/15/2024. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Telephone Status Hearing held on 6/25/2024. Telephone Status Hearing set for 8/8/2024 at 9:00 AM. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Converse Inc. as to certain defendants

NOTICE of Voluntary Dismissal by Converse Inc. as to Certain Defendants

MOTION by Plaintiff Converse Inc. for entry of default as to all Defendants, MOTION by Plaintiff Converse Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Converse Inc. in support of motion for entry of default, motion for default judgment[44]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[45]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 8/8/2024 is vacated. A telephone hearing as to the motion for entry of default and for default judgment [44] is set for 7/16/2024 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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 Thomas M. Durkin: Motion hearing held on 7/16/2024. No one appeared on behalf of defendants. For the reasons stated on the record, the motion for entry of default and for default judgment [44] is granted. Enter order. Civil case terminated. Mailed notice.

DEFAULT Final Judgment Order. Signed by the Honorable Thomas M. Durkin on 7/16/2024. Mailed notice.

MAILED trademark closing report with certified copy of orders dated 7/16/2024 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order[49] in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendant

NOTICE of withdrawal of civil bond [25] by John Summerfield (Received at the Intake Counter on 10/29/24) (Received for docketing 11/21/24)

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendant