2024-cv-05829

COMPLAINT filed by Crista S. Forest; Filing fee $ 405, receipt number AILNDC-22226825.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Crista S. Forest Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Crista S. Forest by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Crista S. Forest by Adam Grodman

ATTORNEY Appearance for Plaintiff Crista S. Forest by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Crista S. Forest by Christopher Romero

ATTORNEY Appearance for Plaintiff Crista S. Forest by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Crista S. Forest by Yanling Jiang

ATTORNEY Appearance for Plaintiff Crista S. Forest by Yi Bu

MOTION by Plaintiff Crista S. Forest for leave to file under seal

MOTION by Plaintiff Crista S. Forest for leave to file excess pages

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 12 13 14 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 $10,000 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 7/16/2024. Notices Mailed.

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

MOTION by Plaintiff Crista S. Forest for preliminary injunction

MEMORANDUM by Crista S. Forest in support of motion for preliminary injunction 21

Declaration of Keith A. Vogt

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

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 21 before Honorable Manish S. Shah on 7/25/2024 at 09:45 AM.

SUMMONS Returned Executed by Crista S. Forest as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/22/2024, answer due 8/12/2024.

(Declaration of Service)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 21 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 7/25/2024. Notices Mailed.

NEW PARTIES: Brave Achiever Technology Limited123, LiuRongSHOP, Phuongphuong2501, Caiqianglinl, He linliang, ZZQSHOP, HYNARTHONG, whfly, weihan66, laohekoushiroudaishangmaoyouxiangongsi, tjp, duola520, wxhcgd, B.Beauty Store, HENANRUWANGGU, ngzhoufengxiangshangmaoyou, MoDiWangLuoKeJi, haideng8364, wuzhengjiangwuzhengjiangmaiha, LinPengShangMao, wengbxy, RunXiBaiHuo, fujunrong1, SanLv, hefeirunqiandianzishangwuyouxiangongsi, 798139026, LEMONCRY, yunxiaoxianjunmaobaihuodian, ZhuoYueXinYou, cxuiiu, Huirui, Yunyang trade, haikousuluoqimaoyiyouxiangongsi, House-Deco, Artwesome Ink, suqiuchahaibaohuihua, JinYan Shop, Spend Ttime, china_culture_5000_years, Shopgametyqb, POUKE, Zunyishihzk, Wang Laistrong clothing, zipuuts43, gzpw, WEIQIER, LZMY and Keluoda added to case caption.

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

MOTION by Plaintiff Crista S. Forest for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Crista S. Forest in support of motion for default judgment 28

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 28 before Honorable Manish S. Shah on 8/20/2024 at 09:45 AM.

[CORRECTED] NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 28 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 7 HYNARTHONG and no. 41 POUKE

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 38 Spend Ttime

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for entry of default judgment 28 is granted. Enter Default Judgment Order. Terminate civil case. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 8/28/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 37 JinYan Shop