2024-cv-05822

COMPLAINT filed by Johanna Katariina Tarkela; Filing fee $ 405, receipt number AILNDC-22226217.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Johanna Katariina Tarkela Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Adam Grodman

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Christopher Romero

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Yanling Jiang

ATTORNEY Appearance for Plaintiff Johanna Katariina Tarkela by Yi Bu

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 by July 25, 2024, the Court may dismiss this matter for failure to prosecute. Mailed notice.

SEALED DOCUMENT by Plaintiff Johanna Katariina Tarkela Schedule A Template Schedule of Defendants to the Complaint 1 and Schedule A 2

MOTION by Plaintiff Johanna Katariina Tarkela for leave to file under seal

MOTION by Plaintiff Johanna Katariina Tarkela for leave to file excess pages

MEMORANDUM in Support of 15 Exparte Motion

Declaration of Keith A. Vogt

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

Declaration of Johanna Katariina Tarkela

(Exhibit 1, of Johanna Katariina Tarkela's Declaration)

SEALED EXHIBIT by Plaintiff Johanna Katariina Tarkela Sealed Exhibit 2, Declaration of Johanna Katariina Tarkela regarding memorandum in support of motion, 16

Exhibit 2-1

Exhibit 2-2

(Exhibit 2-3)

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

SURETY BOND in the amount of $ 10,000.00 posted by Johanna Katariina Tarkela.(Document not imaged) (Received at the Intake counter on 7/23/24)

MOTION by Plaintiff Johanna Katariina Tarkela for preliminary injunction

MEMORANDUM by Johanna Katariina Tarkela in support of motion for preliminary injunction 21

Declaration of Keith A. Vogt

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

SUMMONS Returned Executed by Johanna Katariina Tarkela as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/29/2024, answer due 8/19/2024.

(Declaration of Service)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 21 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining 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 August 1, 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 Johanna Katariina Tarkela regarding text entry, 24

ATTORNEY Appearance for Defendants Alvinma, Coddle HSY, Dalidasy, Deldown, Delicious.C, Extending in all directions, Gallegils, Hinespon, Kelly Mei, Lanege, Langeriy, LeMusi, Linaichen, LWEEIN, Masteelf, Minixin, Nelson Xia, OUNONA Direct, Panyuan001, Pyramid tip, Qumonin, Ranjar, Recardis, Rianley, Sarah Zou, Seriffuali, Shannoy, tracy Zhong, Travelna, WChiho Q, WynBing, Yjiayi, Yvbunfap by Adam Edward Urbanczyk

MOTION by Defendants Alvinma, Coddle HSY, Dalidasy, Deldown, Delicious.C, Extending in all directions, Gallegils, Hinespon, Kelly Mei, LWEEIN, Lanege, Langeriy, LeMusi, Linaichen, Masteelf, Minixin, Nelson Xia, OUNONA Direct, Panyuan001, Pyramid tip, Qumonin, Ranjar, Recardis, Rianley, Sarah Zou, Seriffuali, Shannoy, Travelna, WChiho Q, WynBing, Yjiayi, Yvbunfap, tracy Zhong to set a briefing schedule re: [Dkt. 21] and unseal [Dkt. 17].

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants Alvinma, Coddle HSY, Dalidasy, Deldown, Delicious.C, Extending in all directions, Gallegils, Hinespon, Kelly Mei, Lanege, Langeriy, LeMusi, Linaichen, LWEEIN, Masteelf, Minixin, Nelson Xia, OUNONA Direct, Panyuan001, Pyramid tip, Qumonin, Ranjar, Recardis, Rianley, Sarah Zou, Seriffuali, Shannoy, tracy Zhong, Travelna, WChiho Q, WynBing, Yjiayi, Yvbunfap ("Defendants") have filed a motion seeking to set a briefing schedule and to unseal certain documents. The motion [27] is granted. Plaintiff is directed to provide counsel for Defendants with copies of the materials filed at [17]. Additionally, Plaintiff should submit a revised preliminary injunction order to the Court's proposed Order box excluding these Defendants by August 5, 2024. Finally, Plaintiff and these Defendants are to file a short status report by August 13, 2024 detailing their efforts to settle the matter. To the extent the parties are unable to resolve their differences, they should propose a revised briefing schedule as to any remaining Defendants.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendants Alvinma, Coddle HSY, Dalidasy, Deldown, Delicious.C, Extending in all directions, Gallegils, Hinespon, Kelly Mei, Lanege, Langeriy, LeMusi, Linaichen, LWEEIN, Masteelf, Minixin, Nelson Xia, OUNONA Direct, Panyuan001, Pyramid tip, Qumonin, Ranjar, Recardis, Rianley, Sarah Zou, Seriffuali, Shannoy, tracy Zhong, Travelna, WChiho Q, WynBing, Yjiayi, Yvbunfap. Plaintiff's motion for a preliminary injunction [21] 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 [25] 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. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. 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 Signed by the Honorable Lindsay C. Jenkins on 8/8/2024. Mailed notice.

NEW PARTIES: kunmingshubingshangmaoyouxiangongsi, GLOYER Art, sunmo, Spring Tea Canvas Art, GRAN BEDDING, LONGGOUKUAJING, zhiqing8864, Nareluluio, REALLYINSIDE, Huofenghuang, frcw, Yike Jianshe, huangxiaoyann, BAOBAONIBU, Wu miracle, Giant Trees, Imtos, Mssy, SZDelilong, Fragrant Tea Wall Art, zfangaaa, yi hang wall art and Huaxishui added to case caption.

NEW PARTIES: sdacxzgtrbfdfds, Full of stars.min, huangliangpingamz, Lagercaisser Direct, Likuiy, Edermurs, ZNBHH, Sen M, jianghuaamz, Haizhilan home decoration project, qujingshengcaidianzishangwuyouxiangongsi, KWYUT, wanyn, Shijiazhuang Chisan Trading Company, yuxiqingyaodianzishangwuyouxiangongsi, xiaozhaozhunbeimaidonxi, jzhsq, BAJLDMSHOP, ZAWEYASHOPDM, jiaozuoshishibaoyanjingyouxiangongsi, yahsa, HHWJRZD, Zhahugge, GuangZhouGuiYiShangMao20, SUNQIANGMAIXIGUA, ylu sp, SenNanShangMao559, zhijiangshishimangjiaomaoyidian, linlongyishushangdian, simidamaoyi, UEBXS, Shisuyan, Qiysamall, JMXIANG, Onaparter, Gardnery, Chenpulu, Worgeous, Nishuna, Syudst, LOVERLYZ, Telingmei, YUNXNK and Ndyrrri added to case caption.

NEW PARTIES: Sarasara, LiheShen, JertbinR, Meijiashe, TOPBATHY, ColoredFlr, Mingsyu, Kelingqi, Yuanmiaoke, MYTAKEND, ITEJSC, ShiTianHui, baytrau, PengXiaoYu, Jingfang Stationery store, dssdgdsgs, MENWO, zhouyutaishangmaoy, Zhongmin auto parts store, wangyongqiang, TUNIU Home life, saibinyuxi, Alimb mary, FIYO DIAMOND PAINTING E, FIYO DIY Store, zhaopengfei56299, PingfenweimurUc, Little Urchin, fruodkf5, JohnMalkovichStore, lizhenzhen05, anqiudulingyin, chenguangming8946541, Huoxingren, wanglinboshop, Ailvidong Bags, YIDE, autoroad, wuhonglinshopstate, The green hills surround, Duiruzhao, Grionsy cookies, CGLION Trading, samkaliz, baokuangde changp, Pichichos Mall Store, yuanhaya, fencaixia5974, liujintaoshop, pdorkougior, wamjinkin, cjhfgucyt, FIYO ART C97 Q, unicorninwax, Zaynah2, TSM Store, FIYO DIY ART SHOP, liangxiang5689, litingjie, Huacy, wangbo9349, Defendant 5, Defendant 20, Defendant 57, Defendant 75, Defendant 77 and Defendant 136 added to case caption.

STATUS Report Joint Status Report Pursuant to Minute Entry [18] by Johanna Katariina Tarkela

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff reports that it has reached a settlement in principle with certain remaining Defendants, Alvinma, Coddle HSY, Dalidasy, Deldown, Delicious.C, Extending in all directions, Gallegils, Hinespon, Kelly Mei, Lanege, Langeriy, LeMusi, Linaichen, LWEEIN, Masteelf, Minixin, Nelson Xia, OUNONA Direct, Panyuan001, Pyramid tip, Qumonin, Ranjar, Recardis, Rianley, Sarah Zou, Seriffuali, Shannoy, tracy Zhong, Travelna, WChiho Q, WynBing, Yjiayi, Yvbunfap ("Defendants"). A further status report as to the progress of settlement is due by 9/16/24 to the extent stipulations of dismissal have not been filed.

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

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

MOTION by Plaintiff Johanna Katariina Tarkela for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Johanna Katariina Tarkela in support of motion for default judgment[35]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [35] for entry of default and default judgment against the remaining 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 27, 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. Mailed notice.

CERTIFICATE of Service by Plaintiff Johanna Katariina Tarkela regarding text entry, [37]

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

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

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should re-submit a proposed default judgment order to the Court's proposed order box by the end of the day today. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [35] 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 Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED DEFAULT JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 8/28/2024. Mailed notice.

MAILED Copyright report with certified copy of minute order dated 08/28/2024 to Registrar, Washington DC

MAILED Surety Bond posted by Johanna Katariina Tarkela [20] to Keith A. Vogt via certified mail no. 7019 2280 0000 0962 5070.

RETURN of U.S. Post Office Receipt, article no. 7019 2280 0000 0962 5070.

SATISFACTION of Judgment as to defendant no. 68 HHWJRZD