2024-cv-04156

COMPLAINT filed by Pranash (tianjin) Technology Development Co., Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-21986669.

Schedule A (Redacted)

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(Exhibit 6 (Redacted))

CIVIL Cover Sheet

Notice of Claims by Pranash (tianjin) Technology Development Co., Ltd.

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Complaint

Schedule A

Exhibit 1

Exhibit 6

(Notice of Claims)

SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Exhibit 2A

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Exhibit 2B

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Exhibit 2C

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Exhibit 2D

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(Exhibit Defendant 100)

ATTORNEY Appearance for Plaintiff Pranash (tianjin) Technology Development Co., Ltd. by Nicholas S. Lee

ATTORNEY Appearance for Plaintiff Pranash (tianjin) Technology Development Co., Ltd. by Benjamin Adam Campbell

ATTORNEY Appearance for Plaintiff Pranash (tianjin) Technology Development Co., Ltd. by Sameeul Haque

CASE ASSIGNED to the Honorable Joan H. Lefkow. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 1). (Text entry; no document attached.)

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. (Text entry; no document attached.)

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Manish S. Shah for all further proceedings pursuant to the provisions of 28 USC 294(b). Mailed notice

(Request for reassignment) (ags)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Pranash (tianjin) Technology Development Co., Ltd.

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for Leave to Amend Exhibit 6 and Schedule A to the Complaint

Exhibit 6 (Redacted)

(Schedule A (Redacted))

SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Schedule A

SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Amended Exhibit 6A

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Amended Exhibit 6B

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Amended Exhibit 6C

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SEALED DOCUMENT by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. Amended Exhibit 6D

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MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for temporary restraining order

MEMORANDUM by Pranash (tianjin) Technology Development Co., Ltd. in support of motion for temporary restraining order 21

Declaration of Nicholas S. Lee

(Exhibit 1)

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for Alternative Service

NOTICE of Motion by Sameeul Haque for presentment of motion for miscellaneous relief 23, motion for miscellaneous relief 15, motion for miscellaneous relief 4, motion for temporary restraining order 21 before Honorable Manish S. Shah on 6/19/2024 at 10:00 AM.

NOTICE of Motion by Sameeul Haque for presentment of motion for miscellaneous relief 23, motion for miscellaneous relief 15, motion for miscellaneous relief 4, motion for temporary restraining order 21 before Honorable Manish S. Shah on 6/25/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 4 15 21 23 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $100,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Manish S. Shah on 6/24/2024.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 100,000 posted by Pranash (tianjin) Technology Development Co., Ltd. (Document not scanned)

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. to Extend the Temporary Restraining Order

MEMORANDUM by Pranash (tianjin) Technology Development Co., Ltd. in support of motion for miscellaneous relief 29

(Declaration of Sameeul Haque)

NOTICE of Motion by Sameeul Haque for presentment of motion for miscellaneous relief 29 before Honorable Manish S. Shah on 7/9/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion to extend the TRO 29 is granted. The TRO is extended to 7/22/24. No appearance on 7/9/24 is necessary.

SUMMONS Returned Executed by Pranash (tianjin) Technology Development Co., Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A on 7/15/2024, answer due 8/5/2024.

Declaration of Kathryn Smith

(Exhibit A)

NOTICE of Voluntary Dismissal by Pranash (tianjin) Technology Development Co., Ltd. Under Rule 41(a)(1) madawasi-0 (Def. #25) and zkjie88 (Def. #28) without prejudice

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for preliminary injunction

(Exhibit A)

MEMORANDUM by Pranash (tianjin) Technology Development Co., Ltd. in support of motion for preliminary injunction 35

Declaration of Sameeul Haque

(Exhibit 1)

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. to Extend the Temporary Restraining Order as to Alibaba, Aliexpress, and Shein Defendants

Declaration of Sameeul Haque

(Exhibit 1)

NOTICE of Motion by Sameeul Haque for presentment of motion for miscellaneous relief, 37, motion for preliminary injunction 35 before Honorable Manish S. Shah on 7/18/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion to extend the TRO [37] is denied and plaintiff's motion for preliminary injunction [35] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 7/18/2024. Notices Mailed.

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for preliminary injunction as to the Aliexpress Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 52 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 9/26/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by Pranash (tianjin) Technology Development Co., Ltd. Under Rule 41(a)(1) NYYQYYN (Defendant 4) with prejudice

NOTICE of Voluntary Dismissal by Pranash (tianjin) Technology Development Co., Ltd. as to Def. No. 20

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MOTION by Plaintiff Pranash (tianjin) Technology Development Co., Ltd. for entry of default as to Remaining Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motion for default judgment 62 is granted and after considering the arguments of counsel, the court concludes that a reasonable royalty, inclusive of transaction costs, is $5,000. The court declines to award treble damages because the royalty is high enough to provide deterrence against willful infringement without trebling. The court has doubts about finding this type of infringement on default exceptional and awarding attorney's fees based solely on the defendants' failure to participate. There is nothing exceptional about processing a default on a design patent case where there has been no showing of actual competitive harm and plaintiff is effectively treating the court as a clerical arm of the USPTO. Nevertheless, the court makes the finding and awards the reasonable fee requested to provide an added deterrent to willful infringement. Enter Default Judgment Order. Terminate civil case. Mailed notice

DEFAULT JUDGMENT ORDER signed by the Honorable Manish S. Shah on 1/23/2025. Mailed notice

MOTION by Attorney Edward L. Bishop, Attorney Benjamin A. Campbell, and Attorney Sameeul Haque to withdraw as attorney for Pranash (tianjin) Technology Development Co., Ltd. No party information provided

NOTICE of Motion by Edward L. Bishop for presentment of motion to withdraw as attorney[67] before Honorable Manish S. Shah on 2/19/2025 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion to withdraw as attorney 67 is granted, and no appearance on the motion is necessary. Attorneys Sameeul Haque, Edward L. Bishop, and Benjamin Adam Campbell are terminated as counsel of record. Nicholas Lee remains counsel of record for plaintiff. Notices mailed.