2024-cv-06182

COMPLAINT filed by Shenzhen Jisu Technology Co., Ltd. ; Jury Demand. Filing fee $ 405, receipt number AILNDC-22271312.

Schedule A (Redacted)

Exhibit 1 (Redacted)

Exhibit 2 (Redacted)

Exhibit 3

Exhibit 4

Exhibit 5

(Exhibit 6 (Redacted))

CIVIL Cover Sheet

Notice of Claims by Shenzhen Jisu Technology Co., Ltd.

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for Leave to File Certain Documents Under Seal

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Complaint

Schedule A

Exhibit 1

Exhibit 6

(Notice of Clams)

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Exhibit 2A

Defendant 1

Defendant 2

Defendant 3

Defendant 4

Defendant 6

Defendant 7

Defendant 8

Defendant 9

Defendant 11

Defendant 12

Defendant 13

Defendant 14

Defendant 15

Defendant 16

Defendant 17

Defendant 18

Defendant 19

Defendant 20

Defendant 22

Defendant 23

Defendant 24

Defendant 25

Defendant 26

Defendant 27

(Defendant 28)

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Exhibit 2B

Defendant 29

Defendant 30

Defendant 31

Defendant 32

Defendant 33

Defendant 34

Defendant 35

Defendant 37

Defendant 39

Defendant 40

Defendant 41

Defendant 42

Defendant 43

Defendant 44

Defendant 45

Defendant 46

Defendant 47

Defendant 48

Defendant 49

Defendant 50

Defendant 51

Defendant 52

Defendant 54

Defendant 55

(Defendant 56)

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Exhibit 2C

Defendant 57

Defendant 58

Defendant 59

Defendant 60

Defendant 61

Defendant 63

Defendant 64

Defendant 65

Defendant 66

Defendant 67

Defendant 68

Defendant 69

Defendant 70

Defendant 71

Defendant 72

Defendant 74

Defendant 75

Defendant 76

Defendant 77

Defendant 79

Defendant 80

Defendant 81

Defendant 83

Defendant 84

(Defendant 85)

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Exhibit 2D

Defendant 86

Defendant 87

Defendant 88

Defendant 89

Defendant 90

Defendant 91

Defendant 92

Defendant 94

Defendant 95

Defendant 96

Defendant 97

Defendant 98

Defendant 99

Defendant 100

Defendant 102

Defendant 103

Defendant 104

Defendant 105

Defendant 106

Defendant 107

Defendant 108

Defendant 109

Defendant 110

Defendant 111

(Defendant 112)

SEALED DOCUMENT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Exhibit 2E

Defendant 113

Defendant 114

Defendant 115

Defendant 116

Defendant 117

Defendant 118

Defendant 119

Defendant 120

Defendant 121

Defendant 122

Defendant 123

Defendant 124

Defendant 125

Defendant 126

Defendant 127

Defendant 128

Defendant 130

Defendant 131

Defendant 132

Defendant 133

Defendant 134

(Defendant 135)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Jisu Technology Co., Ltd.

ATTORNEY Appearance for Plaintiff Shenzhen Jisu Technology Co., Ltd. by Edward L. Bishop

ATTORNEY Appearance for Plaintiff Shenzhen Jisu Technology Co., Ltd. by Nicholas S. Lee

ATTORNEY Appearance for Plaintiff Shenzhen Jisu Technology Co., Ltd. by Benjamin Adam Campbell

ATTORNEY Appearance for Plaintiff Shenzhen Jisu Technology Co., Ltd. by Sameeul Haque

CASE ASSIGNED to the Honorable Joan B. Gottschall. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 1). (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.)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff, Shenzhen Jisu Technology Company, Ltd. ("Technology"), represents in its notice of affiliates 11 that it has "no parent corporation owned entirely by Shenzhen Jisu Industrial Holdings Limited ["Holdings"], and that no publicly held corporation owns 10% or more of Plaintiff." First, it is impossible for the court to tell what the relationship between Technology and Holdings is. Second, Local Rule 3.2(a) requires disclosure of all ownership interests meeting the 5% (not 10%) threshold and otherwise meeting the definition of "affiliate." Plaintiff is instructed to file an amended notice of affiliates on or before 7/31/2024 disclosing all individuals and entities required by Local Rule 3.2. Mailed notice

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for extension of time to file Amended Local Rule 3.2 Notice of Affiliates and Disclosure Statement

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Jisu Technology Co., Ltd.

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 17 for an extension to and including 8/2/2024 (this date) of its deadline to file an amended notice of affiliates is granted. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: The minute entry 19 entered 8/05/2024 is corrected to read: Plaintiff's motion 17 for an extension of its deadline to file an amended notice of affiliates is granted. Plaintiff's amended notice of affiliates 18 is deemed timely filed. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: Enter order. In accordance with the order, plaintiff has until and including 8/16/2024 to show cause why joinder of the 135 named defendants is proper. Mailed notice

ORDER Signed by the Honorable Joan B. Gottschall on 8/12/2024. Mailed notice

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for Leave to Amend Schedule A

(Exhibit Amended Schedule A (Redacted))

SEALED EXHIBIT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Amended Schedule A regarding MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for Leave to Amend Schedule A 23

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 23 for leave to amend schedule A of the complaint in order to name a single defendant is granted, as is plaintiff's request that the amended schedule A remain under seal until further order of court. Plaintiff is instructed to file its redacted amended schedule of defendants as a separate docket entry on or before 8/22/2024. Plaintiff's deadline 22 to brief joinder of the former defendants is stricken as moot. Plaintiff is instructed to file a status report on or before 9/5/2024 informing the court of how it intends to proceed.Mailed notice

EXHIBIT by Plaintiff Shenzhen Jisu Technology Co., Ltd. Amended Schedule A (Redacted) regarding complaint, 1

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for temporary restraining order

MEMORANDUM by Shenzhen Jisu Technology Co., Ltd. in support of motion for temporary restraining order 27

Declaration of Nicholas S. Lee

(Exhibit 1)

DECLARATION of Nicholas S. Lee Regarding Notice of Plaintiff's Motion [27]

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for Alternative Service pursuant to Fed. R. Civ. P. 4(f)(3)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 30 under Federal Rule of Civil Procedure 4(f)(3) for leave to serve the summons and complaint by alternative means is denied without prejudice as premature. Plaintiff neither cites nor attempts to distinguish this court's holding in Luxottica Grp. S.P.A. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 391 F.Supp.3d 816, 82128 (N.D. Ill. 2019), that a plaintiff must demonstrate reasonable diligence in determining an international defendant's mailing address before the court can find that the Hague Convention does not apply and authorize service by electronic means. Plaintiff may renew its motion after (1) third-party providers of services to defendants answer plaintiff's discovery requests and (2) plaintiff has conducted a reasonably diligent investigation of any mailing addresses disclosed. Plaintiff has filed a motion 27 for temporary restraining order. Plaintiff's motion is ex parte as to the defendants, but plaintiff has given notice of the motion [28-1] to a non-party service provider named in the proposed temporary restraining order. The third-party provider has until noon on Thursday, 9/5/2024, to object to plaintiff's request that the court find that it has personal jurisdiction over it and that it is in active concert or participation with defendant. See Fed. R. Civ. P. 65(d)(2). The third-party provider may file an objection in writing or request a hearing, to be conducted via teleconferencing, by sending a message to Chambers_Gottschall@ilnd.uscourts.gov, with a copy to all counsel of record, on or before noon on Thursday, 9/5/2024. Plaintiff is ordered to serve the third-party provider with a copy of this order on or before 8/29/2024. Plaintiff must file a certificate of service on or before 8/30/2024. Mailed notice

CERTIFICATE of Service to Third-Party Providers

STATUS Report by Shenzhen Jisu Technology Co., Ltd.

MINUTE entry before the Honorable Joan B. Gottschall: Based on the representations made in defendant's status report 33 filed 9/5/2024, third-party Walmart's deadline to object to plaintiff's motion for a temporary restraining order is extended to noon on 9/12/2024. If no objection or request for hearing is filed by the deadline, the court will rule on the papers. Mailed notice

MINUTE entry before the Honorable Joan B. Gottschall: The deadline 34 of 09/12/2024 to object to, or request a hearing on, plaintiff's motion for temporary restraining order has come and gone, and nothing has been received. Upon consideration of the certificate of service 32 filed 09/03/2024, plaintiff's motion 27 for entry of a sealed temporary restraining order is granted. Enter sealed temporary restraining order. A preliminary injunction hearing to be held by teleconference is tentatively set for 10/09/2024 at 10:30 a.m. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants in the manner specified in the temporary restraining order.Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Joan B. Gottschall on 9/25/2024.Mailed notice

CIVIL BOND in the amount of $ 10,000 posted by Shenzhen Jisu Technology Co. Ltd. (Document not scanned).

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. to Extend the Temporary Restraining Order

MEMORANDUM by Shenzhen Jisu Technology Co., Ltd. in support of motion for miscellaneous relief 38

(Declaration of Sameeul Haque)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff's motion 38 to extend by 14 days the temporary restraining order 36 dated 09/25/2024 is granted. The temporary restraining order is extended to and including 10/23/2024. The preliminary injunction hearing tentatively set for 10/09/2024 is stricken and reset to 10/23/2024 at 10:30 a.m. The preliminary injunction hearing on 10/23/2024 will be held by teleconference. The court will rule on any preliminary injunction motion without holding a hearing unless a hearing is requested at least 48 hours before the time of the scheduled hearing. A hearing may be requested by contacting Judge Gottschall's courtroom deputy at Chambers_Gottschall@ilnd.uscourts.gov. Plaintiff may provide notice of the preliminary injunction hearing to defendants in the manner specified in the temporary restraining order 36. Mailed notice

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for preliminary injunction

(Exhibit A)

MEMORANDUM by Shenzhen Jisu Technology Co., Ltd. in support of motion for preliminary injunction 41

Declaration of Sameeul Haque

(Exhibit 1)

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. For Alternative Service

MINUTE entry before the Honorable Joan B. Gottschall: "Plaintiff's motion 45 for alternative service is granted. Enter order." Plaintiff's motion for preliminary injunction 41 is granted. Enter preliminary injunction order.Mailed notice

ALTERNATIVE SERVICE ORDER Signed by the Honorable Joan B. Gottschall on 10/23/2024. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Joan B. Gottschall on 10/23/2024. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A (Text entry; no document attached.)

SUMMONS Returned Executed by Shenzhen Jisu Technology Co., Ltd. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A on 10/23/2024, answer due 11/13/2024.

Declaration of Kathryn Smith

(Exhibit A)

ORDER: An initial status report is due on or before December 4, 2024. Counsel and parties are directed to familiarize themselves with the pretrial procedures in Judge Gottschall's case management packet, which is available from the court's website at http://www.ilnd.uscourts.gov. Please pay particular attention to the requirement to exchange initial disclosures within 14 days of the parties' initial discovery planning conference and the court's requirement that the parties are to explore settlement opportunities and identify areas of agreement prior to the filing of the first status report. See Fed. R. Civ. P. 26(a)(1)(C) and 26(f)(2). If, by the due date of the scheduled status report, defendants have not been served, plaintiff should send an email to the chambers email account, chambers_gottschall@ilnd.uscourts.gov, to reset the status date. Counsel in cases removed from another court should follow these procedures to the extent applicable. See the order and Judge Gottschall's case management packet for further details. Signed by the Honorable Joan B. Gottschall on 10/30/2024. Mailed notice

MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for entry of default, MOTION by Plaintiff Shenzhen Jisu Technology Co., Ltd. for default judgment as to the remaining Defendant

(Exhibit A)

MEMORANDUM by Shenzhen Jisu Technology Co., Ltd. in support of motion for entry of default, motion for default judgment, 51 as to the remaining Defendant

Declaration of Liang Meiyu

(Declaration of Nicholas S. Lee)

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff has filed a motion 51 for entry of an order of default and a default judgment in the amount of $57,500.67 against defendant FIUION. Any written response to, or request for a hearing on, plaintiff's motion for entry of an order of default against defendant is due on or before December 6, 2024. A hearing, to be conducted via teleconferencing, may be requested by sending a message to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and attorneys who have appeared. If no written response or request for a hearing is received by the deadline, the court will assume that defendant does not oppose the motion and will rule on the papers. Plaintiff is ordered to serve defendant with a copy of this order in accordance with Federal Rule of Civil Procedure 5 and to file a certificate of service on or before November 25, 2024. Mailed notice

CERTIFICATE of Service by Plaintiff Shenzhen Jisu Technology Co., Ltd. regarding set motion and R&R deadlines/hearings, 53

(Exhibit A)

ATTORNEY Appearance for Defendant Inadays by Ruoting Men

MINUTE entry before the Honorable Joan B. Gottschall: Plaintiff represented in its motion [4] to seal schedule A to the original complaint and other documents identifying defendants that sealing was necessary "to prevent the defendants from learning of these proceedings prior to the execution of the temporary restraining order." However, plaintiff never moved for a temporary restraining order, and the case has proceeded to the preliminary injunction stage. Accordingly, plaintiff's motion [4] to seal certain documents identifying defendants is denied without prejudice. The Clerk is instructed to maintain the seal on all documents that are presently sealed until and including 12/18/2024, which is plaintiff's deadline to renew its motion to seal if it wishes to do so. Mailed notice

STATUS Report (Joint) by Shenzhen Jisu Technology Co., Ltd.

NOTICE of Voluntary Dismissal by Shenzhen Jisu Technology Co., Ltd. Under Rule 41(a)(1) FIUION (Defendant #16) with prejudice

MINUTE entry before the Honorable Joan B. Gottschall: Pursuant to plaintiff's notice 58 of voluntary dismissal, this case is dismissed with prejudice. Plaintiff's motion 51 for default judgment is denied as moot. Plaintiff's deadline 56 to renew its motion to seal has come and gone, and no renewed motion to seal has been filed. Accordingly, the Clerk is instructed to unseal all documents in this case. Civil case terminated.Mailed notice