2024-cv-04632

COMPLAINT filed by Triumph International, LLC ; Filing fee $ 405, receipt number AILNDC-22104380.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Triumph International, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Triumph International, LLC for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Triumph International, LLC

Notice of Claims Involving Trademarks by Triumph International, LLC

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiff Triumph International, LLC by Alexander Whang

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 2). (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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff Triumph International, LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief[12]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[13]

Exhibit 1

SEALED EXHIBIT by Plaintiff Triumph International, LLC regarding declaration[14]

Exhibit Exhibit 2, Part 1

Exhibit Exhibit 2, Part 2

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Exhibit Exhibit 2, Part 7

Exhibit Exhibit 2, Part 8

Exhibit Exhibit 2, Part 9

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Exhibit Exhibit 2, Part 11

Exhibit Exhibit 2, Part 12

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Exhibit Exhibit 2, Part 14

Exhibit Exhibit 2, Part 15

Exhibit Exhibit 2, Part 16

Exhibit Exhibit 2, Part 17

Exhibit Exhibit 2, Part 18

Exhibit Exhibit 2, Part 19

Exhibit Exhibit 2, Part 20

Exhibit Exhibit 2, Part 21

Exhibit Exhibit 2, Part 22

(Exhibit Exhibit 2, Part 23)

MOTION by Plaintiff Triumph International, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief[16]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[12], motion for miscellaneous relief[16], motion for miscellaneous relief[3] before Honorable Manish S. Shah on 6/11/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [12] [16] 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 $200,000 is sufficient to secure the injunctive relief. Plaintiff's counsel is warned that joinder of over 200 defendants risks immediate severance (and unsealing of all filings), because it is unlikely that joinder at that scale is appropriate. Enter Sealed Temporary Restraining Order. Notices Mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 6/7/2024. Notices Mailed.

SUMMONS Issued as to Defendant The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $ 200,000 posted by Triumph International, LLC. Document not imaged. (Received at the Intake Counter on 06/14/2024)

MOTION by Plaintiff Triumph International, LLC to Extend the Temporary Restraining Order

MEMORANDUM by Triumph International, LLC in support of motion for miscellaneous relief[22]

Declaration of Martin F. Trainor

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[22] before Honorable Manish S. Shah on 6/20/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [22] is granted, and no appearance is necessary. The TRO is extended to 7/5/24. Notices Mailed.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

SUMMONS Returned Executed by Triumph International, LLC as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 6/28/2024, answer due 7/19/2024.

Declaration of Sydney Fenton

Exhibit A

MOTION by Plaintiff Triumph International, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Triumph International, LLC in support of motion for preliminary injunction[29]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[29] before Honorable Manish S. Shah on 7/3/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [29] is granted in part and denied in part. The motion is granted as to all non-appearing defendants, and is denied as to defendants Noorleather Store and NooraniLeather. Enter Preliminary Injunction Order. Representatives from Noorleather Store and NooraniLeather appeared by telephone and were advised that entities cannot appear in court without counsel. The TRO expires on 7/5/24 and the court expects plaintiff to advise third-party platforms that the TRO has been replaced by the Preliminary Injunction and no asset restraint should be in place against dismissed or excepted defendants. 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 7/3/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NEW PARTIES: 18 Factory Store, Eharlien Official Store, Rock Band T Shirt Store, Shop1102191338 Store, Shop1102828192 Store, Shop1103207139 Store, Shop1103278190 Store, Shop3125025 Store, SUNNY NO.7 Store Store, Wangwang Shop Store, Maxonor-US, 24hourscancontact, a can can, Art-Decore, BHARAT BAZAR CREATION, BINGIGNGINH, BLACK MOON CREATION IND, BOMJJOR, BUNET SHOP, CALENDARMAN, CO CREATIVE, dalinhuazhuangpinmenshibu, deeps4u, DESPERTAR1111, DIYART7, Dizller USA, DreamJ, Dressesify, Elias Gonzalez, Faddy-Rox, FFtto, FHome, gaoyunbo1, guangzhoufanhanmaoyiyouxiangongsi, Hefei mishao Trading Co., Ltd, HOPE&FAITH, JacksonRowe, Jasperz-pvt-ltd, KHASSAN ZHUMAGAZY market, LambsLeather, LaVenty, leather face, LeathersClub Store, Lin Hu Happy, linmeiqinyishuhaibao, M ARSAL STORE, Mary Towns, Melleade, MJ fans (ship time 5-10days) and MJB2C added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

NEW PARTIES: Muuhansic, MyjoyLife, NM Leather City, NYC JACKET, One Cong, PARBHU JI STORE, S,S Store, shenghuabaihuodain, Shop 24x7, SKIN FASHIONS STORE, Slimfitleatherjacket, Sovetov market, StarsJackets, The 3D lab, The 3d lab 2, Trend Leather, Tulip Lake, Unique-Arts, UniqueNO1, UrbanLeatherFactory, Vanesa Roman, Veston Leather Jacket, William Jacket, xiaxiaxiaxingallery, yangjiangshimailinxianshangmaoyouxiangongsi, yejiabinhaibao, YOUQIQI, YUKONSOURCING, Zhonggui Store, AUCRP0LWRSOB7, vingroupshop LED NEON Online Store, carol_store, cow02, qqmall, 2012piaoyanguohai2012, chang-cheng-2022, cute-dragon88, fengtia-32, loveee-84, naby-wang, ya202276, yidai_yilu_2016, zhengfanyuxi-0, autopa_7457, blues_378 and caiyunpiao_39638 added to case caption. (Text entry; no document attached.)

NEW PARTIES: B@MJ.com!, BabiesDecor, CAT Family, Celebjacket, ChandeliersDecor, cryptizen, EZcosplay, fairypocket, gearhumans, hallowitch, Hectee, hozzify, N2 VIBESTORE, one rockin, Owl Harbors, Owl Ohh, owlbumble, owlcartels, OWLCONOR, Owls Matrix, OwlTrending, resttee, sgatee, sherateen, storecloths, teegino, valkyre, wanahavit, wbmtee, webcosplay, wesellanything, wispmerch, Child's VoicCac, Debora Ribeiro, Iain Mcgregor, FlorismartBrian, Herbertas Kazlaukas, Jasapparell, Juanjo Magana, Miltossavvides, MintuDutta1, OttmarSchlute, Pik26shop, AAA Art, Album Canvas, Cool Goods Collected, funsweet, Jun poster board, ModificationClub, Nanatongxue, SUMMER CRAFTS, T T canvas print, TSY Phone Case, BINFA-Wall Art, Anime Paradise Store, Dodnjka562, grwoerihzxnz, GUOFAN5, HaogeZshop, lindanping1189, mengxin1994, qingyanph, tanyuanshihui, yangwenhai025621 and zhaoxiaoyun6062 added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to certain Defendants

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

NOTICE of Voluntary Dismissal by Triumph International, LLC as to a certain defendant

MOTION by Plaintiff Triumph International, LLC for entry of default, MOTION by Plaintiff Triumph International, LLC for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Triumph International, LLC in support of motion for entry of default, motion for default judgment[51]

Exhibit 1

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[52]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment[51] before Honorable Manish S. Shah on 11/7/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment [51] is granted. Enter Default Judgment Order. Although the court authorizes service of the judgment order on Third Party Providers by email, it does not conclude that email delivery on those providers is conclusively effective. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 11/7/2024. Notices Mailed.

FULL SATISFACTION of Judgment as to a certain defendant

FULL SATISFACTION of Judgment as to a certain defendant