2024-cv-04259

COMPLAINT filed by Bryan Fletcher, Garrett Fletcher; Filing fee $ 405, receipt number AILNDC-22005889.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Schedule A regarding complaint[1]

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for leave to file under seal

CIVIL Cover Sheet

Notice of Claims Involving Trademarks by Bryan Fletcher, Garrett Fletcher

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for temporary restraining order[10]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[11]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Steve Fletcher regarding memorandum in support of motion[11]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Exhibit 3 - Parts 1 - 7 regarding declaration[13]

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for miscellaneous relief[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file[3], motion for temporary restraining order[10], motion for miscellaneous relief[15] before Honorable Manish S. Shah on 5/30/2024 at 09:45 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MINUTE entry before the Honorable Manish S. Shah: Plaintiffs' ex parte motions [3] [10] [15] are granted, and no appearance on the motions is necessary. The plaintiffs' written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiffs' 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 plaintiffs is irreparable and an injunction is in the public interest because infringement interferes with the plaintiffs' ability to control their 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 $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 5/30/2024. Notices Mailed.

Registry Deposit Information Form by Bryan Fletcher, Garrett Fletcher

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

SURETY BOND in the amount of $ 50,000 posted by Bryan Fletcher (Document not scanned).

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for preliminary injunction[24]

Declaration of Trevor C. Talhami

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for preliminary injunction[24] before Honorable Manish S. Shah on 6/13/2024 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/10/2024, answer due 7/1/2024.

Declaration of Luana Faria de Souza

Exhibit A

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin Tyler Joseph

TRANSCRIPT OF PROCEEDINGS held on 06/13/2024 before the Honorable Manish S. Shah. Motion Hearing. Order Number: 49044. Court Reporter Contact Information: Colleen_Conway@ilnd.uscourts.gov or 312.435.5594. 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 7/4/2024. Redacted Transcript Deadline set for 7/15/2024. Release of Transcript Restriction set for 9/11/2024.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [24] 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 6/13/2024. Notices Mailed.

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/20/2024, answer due 7/11/2024.

Declaration of Luana Faria de Souza

(Exhibit A)(Faria De Souza, Luana)

NEW PARTIES: Chengdu Quilimen Business Co., Ltd., Dongguan Huayi Gift Packaging Co., Ltd., Dongguan Jialedi Toys Co., Ltd., Dongguan Shenzhan Electronic Technology Co., Ltd., Dongyang Xingyue Festival Articles Co., Ltd., Guigang Younger Craftwork Co., Ltd., Hangzhou Yiqin Trading Co., Ltd., Ningbo General Union Co., Ltd., Qingdao Starry Supply Chain Management Co., Ltd., Shanghai Gravim Industrial Co., Ltd., Shenzhen Leguoguo Trading Co., Ltd., Shenzhen Livoti Electronic Techenology Limited, Shenzhen Panda Technology Co., Ltd., Shenzhen Shunbang Technology Co., Ltd., Shenzhen Youfang Industry Co., Ltd., Yangzhou East Imp.& Exp. Co., Ltd., Yiwu Feijia Trading Co., Ltd., Yiwu Flowers Sweet Maternal And Infant Supplies Co., Ltd., Yiwu Lihong E-Commerce Co., Ltd., Yiwu Musa Handicraft Co., Ltd., Yiwu Shangyi Garment Co., Ltd., Yiwu Shengge Bag Factory, Yiwu Yh Art & Crafts Co., Ltd., Yiwu Youcan Imp. & Exp. Co., Ltd., Yiwu Zhiyi Trading Co., Ltd., A1MSU1ELD0BQKA, A3TS5UZ5OK74CO, aiyexiangmaoyiyouxiangongsi, angxingyang6688, BaoShengFuTai, BINBINTOYS US, CHEN1LIN1YAN, dangshancaipingwangluokejiyouxiangongsi107, dunyunqiashangmaoyouxiangongsi, ezhoushifengfenglishangmaoyouxiangongsi, Guangraotaidaoshangmao, GuangZhouJiLuDianZiShangWuYouXianGongSi, guchengxianwenbengshangmaoyouxiangongsi, Gusu foreign trade, hefeigunongdianzishangwuyouxiangongsi, HongYanQingUS, huangxinlong2, Inkspire World, JingMenShiGuiWangShangMaoYouXianGongSi, KDIDFDD, kunmingwuhuamingzhikuiwangluokejiyouxiangongsi, lijiangdedian, liujianingdedian, LLIIHANG, LLOONNGG, MaoRenJie, paipailifushi, qiongyingronghuafushi, RuiDing123, SCHShop, shanxidiyuejinzhenshangmaoyouxiangongsi, shenshen-q, SHUAI-US, TangFuDianZiShangWu, WWANGEN, xiangyangshilanlirongshangmaoyouxiangongsi, xiaoyachaoshe, xiekundexiaodian, xingtaipaiboshangmaoyouxiangongsi, xingtaishijianbiewenhuachuanboyouxiangongsi, Yanhaoshop, YiChunJiaXinTongDianZiShangWuYouXianGS, YJSHOP happy, Zenith Young Grand, zhangmei Chen, Zhengsm, zhengzhouaikunxinxikejiyouxiangongsi, zhengzhoumacenmaoyiyouxiangongsi, zhongxiangshichengqinghaoshangmaoyouxiangongsi, zhoutongyiliao, ZHOUWU Store, ZMUUA ONLINE, ZZW store, Led lightFace mask store, Plush Toys, adfkjg, baijiaxinyong, cha1-14, chenxinyuan_6, czvuhg, huangwei10, huihuang_5, lidufgh, panti-92, qingqing-9, sansastg, sjune86, wenb199, xzongtoy, youmelove, 101279688, HTDD, MaoQianQian, WuChenXu and xuxuzehui added to case caption.

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for entry of default, MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for entry of default, motion for default judgment, [34]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[35]

Exhibit 1

NOTICE of Motion by Trevor Christian Talhami for presentment of motion for entry of default, motion for default judgment, [34] before Honorable Manish S. Shah on 7/18/2024 at 09:45 AM.

Exhibit A

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Rachel S Miller

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment [34] is granted. Enter Default Judgment Order. Civil case terminated. Notices Mailed.

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

FULL SATISFACTION of Judgment regarding order 40 in the amount of $150,000 as to certain defendants

NOTICE of withdrawal of bond 23 by John Summerfield

MAILED trademark report with certified copy of minute order dated 7/18/2024 to Patent Trademark Office, Alexandria VA. (jn,)