2024-cv-06282

COMPLAINT filed by NHL Enterprises, L.P.; Filing fee $ 405, receipt number AILNDC-22280191.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff NHL Enterprises, L.P. Schedule A regarding complaint[1]

MOTION by Plaintiff NHL Enterprises, L.P. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by NHL Enterprises, L.P.

Notice of Claims Involving Trademarks by NHL Enterprises, L.P.

ATTORNEY Appearance for Plaintiff NHL Enterprises, L.P. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff NHL Enterprises, L.P. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff NHL Enterprises, L.P. by Allyson M. Martin

ATTORNEY Appearance for Plaintiff NHL Enterprises, L.P. by Kahlia Roe Halpern

CASE ASSIGNED to the Honorable Matthew F. Kennelly. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2).

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.

MOTION by Plaintiff NHL Enterprises, L.P. for temporary restraining order Including a Temporary Injunction, Temporary Transfer of the Domain Names, Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by NHL Enterprises, L.P. in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Lindsay Conn regarding memorandum in support of motion[12]

SEALED EXHIBIT by Plaintiff NHL Enterprises, L.P. Exhibit 1 - Parts 1-10 regarding declaration[14]

SEALED EXHIBIT by Plaintiff NHL Enterprises, L.P. Exhibit 1 - Parts 11-19 regarding declaration[14]

DECLARATION of Thomas H. Prochnow regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

MOTION by Plaintiff NHL Enterprises, L.P. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by NHL Enterprises, L.P. in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal 3 and motion for electronic service of process 18 are granted. Plaintiff's ex parte motion for entry of a temporary restraining order (etc.) 11 is granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 8/12/2024 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207, access code 980-394-33. Motion for preliminary injunction or motion to extend TRO must be filed by 8/7/2024. Any motion for preliminary injunction filed in this case must be accompanied by a certificate stating upon whom and how the motion has been served. In addition plaintiff is advised that summons is to be electronically served in a prompt fashion and that plaintiff should not wait until close to the preliminary injunction hearing to serve summons. The Court advises that if plaintiff contravenes this direction any motion for preliminary injunction may be denied and the TRO may expire. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 7/29/2024.

Registry Deposit Information Form by NHL Enterprises, L.P.

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

NOTICE of Voluntary Dismissal by NHL Enterprises, L.P. as to a Certain Defendant

MOTION by Plaintiff NHL Enterprises, L.P. for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by NHL Enterprises, L.P. in support of motion for preliminary injunction 25

DECLARATION of Allyson M. Martin regarding memorandum in support of motion 26

(Exhibit 1)

SUMMONS Returned Executed by NHL Enterprises, L.P. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/5/2024, answer due 8/26/2024.

Declaration of Kahlia R. Halpern

(Exhibit A)

MINUTE entry before the Honorable Matthew F. Kennelly: Summonses in this case were not electronically served until 8/5/2024, the same day plaintiff filed its motion for preliminary injunction. In the Court's view, this does not give the defendants sufficient time to respond to the preliminary injunction motion. The Court at its own instance therefore extends the temporary restraining order through 8/22/2024 and resets the 8/12/2024 preliminary injunction hearing to 8/22/2024 at 9:00 AM. The following call-in number will be used for the hearing: 650-479-3207, access code 980-394-33.

INJUNCTION BOND in the amount of $ 10,000.00 posted by NHL Enterprises, L.P. (Document not scanned)

MOTION by Plaintiff NHL Enterprises, L.P. for preliminary injunction as to certain Defendants

Exhibit A

MEMORANDUM by NHL Enterprises, L.P. in support of motion for preliminary injunction[31]

Declaration of Allyson M. Martin

Exhibit 1

SUMMONS Returned Executed by NHL Enterprises, L.P. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/15/2024, answer due 9/5/2024.

Declaration of Kahlia R. Halpern

Exhibit A

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff has at this point filed two separate preliminary injunction motions that cover all defendants named in the case. There are currently two separate draft orders that have been submitted. Plaintiff is directed to promptly provide to Judge Kennelly's proposed order e-mail address a single draft preliminary injunction order that includes all defendants.

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or a response to the complaint or an objection to the motion for preliminary injunction. Plaintiff's motions for entry of a preliminary injunction are granted 25 31. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The preliminary injunction hearing set for 8/22/2024 is vacated. The case is set for a telephonic status hearing on 10/30/2024 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207, access code 980-394-33. Plaintiff is directed to file a status report on 10/23/2024. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 8/21/2024. Mailed notice.

NEW PARTIES: Cixi Xizhixi Trade Co., Ltd., Guangzhou Winspeed Garment Accessories Co., Ltd., Guangzhou Winstar Beauty Technology Co., Ltd., Guangzhou Yalite Trading Co., Ltd., Hangzhou Arthur Gifts Co., Ltd., Nanchang Yuesanxing International Trade Co., Ltd., Nanjing New Zhaogy Tech. Dev. Co., Ltd., Quanzhou Geyou Trading Co., Ltd., Quanzhou Huazhi Shengfang Crafts Co., Ltd., Quanzhou Weike Shoes Co., Ltd., Shanghai Pdyear Co., Ltd., Wuhan Letgoal Sporting Goods Co.,Ltd, Wuxi Yinbangke Import And Export Trading Co., Ltd., Yiwu Babie Jewelry Co., Ltd., Yiwu Benli E-Commerce Firm, Yiwu Chancy Garment Accessories Co., Ltd., Yiwu Chennan Electronic Commerce Firm, Yiwu Maige Jewelry Firm, Zhejiang Ealer Sports Goods Co., Ltd., A1BMHGZN7N4LTP, AAPT14NN8DJ94, AFS49941RUPGB, ChaoFengN, DAGNI&CAR, guangzhoukongchaoshangmaoyouxiangongsi, GuChengXianZhiJiuHuaShangMaoYouXianGongSi, GZY SHOP, hangzhoujingchuanwangluokejiyouxiangongsi, HGSD SHOP, HUIHUIXIAO, JERSEY_SHOP, Liaoyp shop, LIKilin, Lomoyato, LWangxy shop, maizebaihuo, PT PECTNK, RuiMao TJ, Shengyang Shop, SIR WAN, siyi store, SPORT JERSEYS, Sunny Shop, WangKaiShangMaoBaiHuoDian, wei jie sheng shang mao gong si, WENJIE STORE, XiaoShenShangMaoDian018, YANYONGLAN, yichangshihualilaishangmaoyouxiangongsi, YingTaoJie, YiXinQ, zhenjiangxinqupingchangdanchuanghuazhuangpindian, ajshoes188, alljerseys66, ball2005, custom145, designer_clothing711, dhgatesvip6, fashionseller11, fashionshoes010, fashionshoes32458, fashionshoes8086, forbesjersey, fzcte1, great_jersey_store, hot_new_store, jerseynhl11, jerseyqwe11, jerseystore5888, liangyu10, mlbjersey333, necklacktiffany, nfl_jerseysone5, nfljersey0001, nnbbllssjersey5200, s3599, s7363, seller8235, seller8931, specia_jerseys_store, stitched_top_jersey, super_jersey_factory, union_jersey_factory, wangguangyao123, 2cad_79, aaj545, anv6i_15, giaho64, giai74, heweisheng031, nguyedu_32, StarlightSSS, tanyulinta, weicx-06, zhuoxin1966, Liweiya, QYSHoping, apexjerseys.shop, jacksportshop.com, kongdoo, Q03BOAHJ4, SDFGTHH, UCJRSIQOQ, ocasionshop.com, sabresedgestore.com, avalanchegearfanstore.com, storet-shirt.com, btfclothing.com, kingteeshops.com, shopstees.com, nikkoil.com, hayateclothing.com, bestteestore.net, 365daysclothing.com, boutfitstore.com, btfstore.com, coolgift99.com, flagwavers89.com, timestshirt.com, lasport247.com, lydialucy.com, miximerch.com, sportlowprice.com, sportzgears.com, star-fashionshop.com, supergift99.com, teepublicity.com, thegiftlux.com, jacketsluxury.com, trendsclothing-shop.com, ciaosoos.com, hurricanesapparelshop.com, oilersapparelshop.com, rangersapparelshop.com, floridapanthersstore.com, penguinsfansteamstore.com, flamesfanshop.com, bruinsshopofficial.com, knightsstoreonline.com, avalancheteamstore.com, avalanchefanproshop.com, rangersteamonlinestore.com, predatorsteamprostore.com, rangersnhlstore.com, shopteamrangers.com, penguinsfansproshop.com, flamesboutiquestore.com, shopcapitals.com, shopthenewyork.com, nashvillepredatorsshop.com, nashvilleoutletshop.com, sportings-boutique.com, 23jerseyshop.com, jerseydeal.org, specialitystore.org, jerseycollection.org, faninsports.com, jerseystoreofficial.com, sportjerseystore.org, hockeyjerseysglobal.com, hockeyusajerseys.com, projerseys.shop, fanaticsjersey.org, officialjerseys.net, hockeyjerseysshoponline.com, jerseysstoresite.com, jerseyshopy.com, jerseyworlds.com, hockeyglobaljerseys.com, officialjerseyshopline.com, myjerseyhub.com, jerseysstoretop.com, onlinejerseysnet1.com, jersey30.com, topyouds.shop, jerseysporting.com, jerseysglobal.com, jerseyonlinestore.com, jerseyofficialsales.com, icehockeyjerseymall.com, poqmall.com, nasportstrophy.com and kilibuyrings.club added to case caption.

MINUTE entry before the Honorable Matthew F. Kennelly: Order: It has come to the Court's attention that the access code for its telephonic conference line was changed without notice. For any telephonic hearing set in this case the following call-in number will be used: 650-479-3207; access code 2305-915-8729. That is the number that should be used for any telephonic hearing in this case after today's date. Mailed notice

ATTORNEY Appearance for Defendants Wuhan Letgoal Sporting Goods Co.,Ltd, Zhejiang Ealer Sports Goods Co., Ltd. by Adam Edward Urbanczyk

MOTION by Defendants Wuhan Letgoal Sporting Goods Co.,Ltd, Zhejiang Ealer Sports Goods Co., Ltd. for extension of time UNOPPOSED

MINUTE entry before the Honorable Matthew F. Kennelly: Unopposed motion by defendants Wuhan Letgoal Sporting Goods Co.,Ltd, Zhejiang Ealer Sports Goods Co., Ltd. for extension of time [39] is granted; response to complaint is to be filed by 10/14/2024. This does not affect any other date or deadline set by the Court.

MOTION by Plaintiff NHL Enterprises, L.P. for entry of default as to Certain Defendants, MOTION by Plaintiff NHL Enterprises, L.P. for default judgment as to Certain Defendants

Exhibit A

MEMORANDUM by NHL Enterprises, L.P. in support of motion for entry of default, motion for default judgment, [41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

FINAL DEFAULT JUDGMENT ORDER AS TO CERTAIN DEFENDANTS signed by the Honorable Matthew F. Kennelly on 9/25/2024: Motion for entry of default judgment as to certain defendants [41] is granted.

ATTORNEY Appearance for Defendants Shanghai Pdyear Co., Ltd., Wuxi Yinbangke Import And Export Trading Co., Ltd. by Adam Edward Urbanczyk

MOTION by Defendants Wuhan Letgoal Sporting Goods Co.,Ltd, Zhejiang Ealer Sports Goods Co., Ltd. for extension of time UNOPPOSED

MINUTE entry before the Honorable Matthew F. Kennelly: Unopposed motion by certain defendants for extension of time [46] is granted; response to complaint is to be filed by 11/14/2024.

STATUS Report per [35] by NHL Enterprises, L.P.

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has reviewed plaintiff's status report. The telephonic status hearing set for 10/30/2024 is vacated and reset to 12/5/2024 at 9:10 AM. The following call-in number will be used for the hearing: 650-479-3207, access code 2305-915-8729. A status report with a proposed discovery and pretrial schedule as to all remaining defendants is to be filed on 11/27/2024.

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, terminate motions[44] in the amount of $100,000 as to certain defendants

STATUS Report per [49] by NHL Enterprises, L.P.

MINUTE entry before the Honorable Matthew F. Kennelly: The Court has reviewed plaintiff's status report. The telephonic status hearing set for 12/5/2024 is vacated and reset to 12/20/2024 at 9:30 AM. The following call-in number will be used for the hearing: 650-479-3207, access code 2305-915-8729. Motions for consent judgment are to be filed by 12/17/2024.

MOTION by Plaintiff NHL Enterprises, L.P. to approve consent judgment as to Defendant Nos. 12 and 19

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to approve consent judgment 53 is granted. Consent Judgment Order to follow. Any hearing dates before this Court are stricken. Civil case terminated. Mailed notice.

CONSENT ORDER: Signed by the Honorable Matthew F. Kennelly on 12/18/2024. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 12/18/24 to Patent Trademark Office, Alexandria VA

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, terminate motions[44] in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order on motion for entry of default, order on motion for default judgment, terminate motions[44] in the amount of $100,000 as to certain defendant