2024-cv-05330

COMPLAINT filed by Tammie DeAnne Hunter; Filing fee $ 405, receipt number AILNDC-22182355.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Tammie DeAnne Hunter schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Yanling Jiang

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Yi Bu

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Adam Grodman

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Tammie DeAnne Hunter by Christopher Romero

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category 3).

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 Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. If the template is not completed and filed by July 11, 2024, the Court may dismiss this matter for failure to prosecute. Mailed notice.

SEALED DOCUMENT by Plaintiff Tammie DeAnne Hunter Schedule A Template Schedule of Defendants to the Complaint 1 and Schedule A 2

MOTION by Plaintiff Tammie DeAnne Hunter for leave to file under seal

MOTION by Plaintiff Tammie DeAnne Hunter for leave to file excess pages

MEMORANDUM in support of 15 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of of Keith A. Vogt's declaration

Declaration of Tammie DeAnne Hunter

(Exhibit 1, of Tammie DeAnne Hunter's declaration)

SEALED EXHIBIT by Plaintiff Tammie DeAnne Hunter Sealed Exhibit 2, Declaration of Tammie DeAnne Hunter regarding memorandum in support of motion, 16

Exhibit 2-1

(Exhibit 2-2)

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

SURETY BOND in the amount of $10,000 posted by Tammie DeAnne Hunter. (Document not scanned)

MOTION by Plaintiff Tammie DeAnne Hunter for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for an extension of the TRO 21 is granted. The TRO is extended to August 8, 2024. Mailed notice.

MOTION by Plaintiff Tammie DeAnne Hunter for preliminary injunction

MEMORANDUM by Tammie DeAnne Hunter in support of motion for preliminary injunction 23

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

SUMMONS Returned Executed by Tammie DeAnne Hunter as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/23/2024, answer due 8/13/2024.

(Declaration of Service)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 23 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by July 29, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff Tammie DeAnne Hunter regarding text entry, 26

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction 23 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established 27 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Jiangip Llc, is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order by the Honorable Lindsay C. Jenkins on 7/30/2024. Mailed notice.

NEW PARTIES: Blueangle, SIGOUYI, Anna Cowper, zhangjianc3066, AHCDH, OPRINT, Vandarllin, zhangy5577, TZJ HOME, waerte, limeng9342, SHIGUANGXIANGRIKUI, KEEPREAL, BEIRTY, DOME-SPACE, JCTEEN, MSQMY, HOA TUNOM, BEAunai shop, lupengj988, Chic D, wucaiy6432 and shanwenchang added to case caption.

NEW PARTIES: LBDecor and YOUNGKIDS added to case caption.

NEW PARTIES: Blueangle, SIGOUYI, Anna Cowper, zhangjianc3066, AHCDH, OPRINT, Vandarllin, zhangy5577, TZJ HOME, waerte, limeng9342, SHIGUANGXIANGRIKUI, KEEPREAL, BEIRTY, DOME-SPACE, JCTEEN, MSQMY, HOA TUNOM, BEAunai shop, lupengj988, Chic D, wucaiy6432 and shanwenchang added to case caption.

NEW PARTIES: Heart Pain, Sicily wall decor, Doe 188 lxooo, lxooo, OLZLO, Pangeelia, FJDENG, Saobao, BHGRMY, TengZhiZe, BedBed UP, KikandKo, vvfuhuishangmao, EMPOROYA, JinXiangRY, FHTDZH, vanvuong1819, Daoduy638188, Thiengiangrrantrannyyt55, AGAWIJ, YETTASBIN, Locphuho store, chuzhouyuanwendianzishangwuyouxiangongsi, huangyufeidedian, Victories, zhijiangshigongchuitushangmaoxing, Artistic Curtain, ezhoushihongmubaihuoshanghang111, Delighin346, WU HU, kunmingyanrendianzishangwuyouxianzerengongs i, hongshishangmao, ZhaoYangTU, PanwangTan Toys Co., Ltd., Linyov inc, LONGA ENTERPRISES LLC, Cloudyff, Halo Trading Co., Ltd, factorysalesstore, guangxiyudi, BONTOO, BAGGJMYLLC, GuangZhouYangZhuShangMaoYouXianGongSi and vrfejkl1n added to case caption.

NEW PARTIES: Defendant 14, Defendant 41, Defendant 44, Defendant 52 and Defendant 54 added to case caption.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

MOTION by Plaintiff Tammie DeAnne Hunter for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Tammie DeAnne Hunter in support of motion for default judgment 31

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 31 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before August 21, 2024. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service.

CERTIFICATE of Service by Plaintiff Tammie DeAnne Hunter regarding text entry, 33

ATTORNEY Appearance for Defendants BedBed UP, Chic D, DOME-SPACE, Heart Pain, LBDecor, Pangeelia, Vandarllin, Victories, YOUNGKIDS, huangyufeidedian by Timothy Tiewei Wang

Exhibit A - List of Represented defendants

MOTION by Defendants BedBed UP, Chic D, DOME-SPACE, Heart Pain, LBDecor, Pangeelia, Vandarllin, Victories, YOUNGKIDS, huangyufeidedian for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants' Victories, Vandarllin, Pangeelia, BedBed UP, LBDecor, YOUNGKIDS, Chic D, Heart Pain, Huangyufeidedian, and DOME-SPACE's unopposed motion for an extension of time to answer 36 is granted. These Defendants' answer is now due by September 11, 2024. Plaintiff should submit a revised default judgment order to the Court's proposed order box by August 23, 2024 that omits these Defendants from the Order. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The following Order does not apply to Defendants Victories, Vandarllin, Pangeelia, BedBed UP, LBDecor, YOUNGKIDS, Chic D, Heart Pain, Huangyufeidedian, and DOME-SPACE. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 31 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's marks irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants (Plaintiff has failed to seek an accounting of profits), the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $50,000 is an appropriate award of statutory damages. Enter Partial Final Judgment Order. Mailed notice.

ENTERED PARTIAL DEFAULT JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 8/27/2024. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: No responsive pleading was filed by the last remaining Defendants (Victories, Vandarllin, Pangeelia, BedBed UP, LBDecor, YOUNGKIDS, Chic D, Heart Pain, Huangyufeidedian, and DOME-SPACE) by the September 11, 2024 deadline [see [37]]. Plaintiff is to file a short report by September 25, 2024, indicating whether any Defendants remain in the case, otherwise the Court intends to close the matter. Mailed notice.

STIPULATION of Dismissal Joint Stipulation of Dismissal as to [Certain] Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: A stipulation of dismissal [42] having been filed as to the remaining Defendants, the clerk is directed to close the case. Civil case terminated. Mailed notice.

MAILED copyright report with order dated 9/24/2024 to Registrar, Washington DC