2024-cv-06848

COMPLAINT filed by Jennifer Lambein; Filing fee $ 405, receipt number AILNDC-22325923.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Jennifer Lambein Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Adam Grodman

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Christopher Romero

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Monica Rita Martin

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Yanling Jiang

ATTORNEY Appearance for Plaintiff Jennifer Lambein by Yi Bu

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 3). (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.)

MAILED Copyright report to Registrar, Washington DC

MOTION by Plaintiff Jennifer Lambein for leave to file under seal

MOTION by Plaintiff Jennifer Lambein for leave to file excess pages

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 12 13 14 are granted. 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 $200,000 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 8/12/2024. Notices Mailed.

MOTION by Plaintiff Jennifer Lambein for extension of time for Temporary Restraining Order

NOTICE of Motion by Keith A. Vogt for presentment of extension of time 22 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

MOTION by Plaintiff Jennifer Lambein for preliminary injunction

MEMORANDUM by Jennifer Lambein in support of motion for preliminary injunction 24

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 24 before Honorable Manish S. Shah on 8/28/2024 at 09:45 AM.

SUMMONS Returned Executed by Jennifer Lambein as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/19/2024, answer due 9/9/2024.

(Declaration of Service)

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 22 is granted. The TRO is extended to 9/9/24.Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 24 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 8/28/2024. Notices Mailed.

NEW PARTIES: Personalized wall plate, wudijunyishangmao, yuxingjing, Nokopwiuv, xujing3404, putianshilichengqugulariyongpindian, CHENXIANGGUIMAIYIFU, zzdlileshangmao, ngzhoufengxiangshangmaoyou, kantcute, bdywuno, weifangqianyidianzishangmaoyouxiangongsi, hausgd, hefeifengmingdianzishangwuyouxiangongsi, jhkhk, zhangzhichengcheng, panlongqusichaobaihuoshanghang, Defendant No. 18, rui shop, xwrggf, sujubaihuoxiaoshou, XTYKongHu, epengshangmao, baodingkuikuwenhuachuanboyouxiangongsi, kunmingaoxuanshangmaoyouxiangongsi, KE brant, ingtongguanshangmaoyo, SuLianShangMao126, xiangyangshixiangchezhuyuanshangmaoyouxiangongsi, cqxly, miaomansenstore, denwcsg, yxxi sp, mmie, Defendant No. 35, zhoutonghanshangm, Tibetan Spring, huanfu4060, SenTongShangMao, BZSXXDZSWYXGS, yangxiaolongzhixiaoyinshangmao and SenNanShangMao559 added to case caption. (Text entry; no document attached.)

NEW PARTIES: Defendant No. 43, gongjunhuachipingguo, LIJUNMAIYIFU, GuangZhouGuiYiShangMao20, gddeei, Yesunpxs Fashion, LSLJS, clearance sales today deals prime deals of the day, Dreamlascar, NaRHbrg, Vifucz, LMSXCT, huizerujielou, black friday deals 2023, Dovford, whfly, Likangkang, Limeishangmao, hanshanxisidianzishangwugongzuoshi, TianLangShangMao, Mmddbart, xiang art shop, junlii3182, liyengsa, guang zhao, MYARTSTORE, WDD-ART, liuhaitaofafafa, VIta Home&Decor, Yang Clothing Store, Miayilima LLJBD, Zainafacai, DiManFeng Inc, MFJA Store, Beppter Learning, Feltree, piaybook, HeZeFengGangWang, Fastest Shipping, duohahaa, LIU Clothes Store, Leodye, HuiRuMao Co.Ltd, Wbecky and WQJNWEQ (USA) added to case caption. (Text entry; no document attached.)

NEW PARTIES: Deagia, Oneshit sales promotion, Puhuiying, WZHXIN Sales Store, Fnyoxu, HACHUN, Zelnk, GKNBC, Japceit, XDXSSM, ZUOZUOFANGQAQ, TuAnn, Fimeskey, ZYNIC, SHENZHENSHIJIANGJINGWANJUYOU XIANGONGSI, JiangQiang Co., LTD, CYRMKJIUHS, GMAmn, CRCMJUHGSA, UOHEYT, EOnmo, ZBBMUYHGSA, health1998, LuLin, XunRui, AoDingDe Co.Ltd, JiaChangwang Co., LTD, MagicXflow, guangzhouyanghongyunkejiyouxiangongsi, WAlgn, SYCMKUH, Okaydehi, haisenfanshangmao, Ye Ye Bu Ao Ye store, Yuanhao Auto Parts store, GuangZhouYangZhuShangMaoYouXianGongSi, KunMingTaoFuWangLuoKeJiYouXianGongSi, Run headset store, YinShiYu001, Jiajia Department Store, zipuuts43, TUNIU Home life and HeBeiChen added to case caption. (Text entry; no document attached.)

NEW PARTIES: JiJiaYing, bmange, Qianjingfeng Co., Ltd., jieadkavo, Sunggoko, Adzgya, Outoloxit, PANRICH, Lemononstore, LYGFSRDX, GINFENP, Kaixunba Co., Ltd., Jingzi Co., LTD, Tianfeng Co., LTD, JinBoXin Co., LTD, HGEGPO, SLHLJlin, Lizian Co., Ltd., BTTGGLhn, FANX, liufngyn, Zeeyou Co.Ltd, LBCHEN Clearance Sold, Ctnporpo Home, TunChangWeiBangXianShangMaoYouXianGongSi, GuiYuFeiWireless, laoshi, liwan2hao, Erqing e-commerce Co., LTD, YMARPT, WYBXZ, Ying Xin Co., LTD, Keeplus, Home Essential Pro, KYWHSGABRS, vovofine Co., LTD, HongchengLong Co., LTD, Haoji Co., Ltd., MOTAO.Co.Ltd, laiyuwen, LUOzoyuans, TJJMKIJSHUGDS, XiLanHUA, HAPIMO, Scyoekwg and NaRHbrg added to case caption. (Text entry; no document attached.)

NEW PARTIES: Baoyu Men's Clothing store, Lee menswear store, YOUlIAN Co.Ltd, DFERTY CO.Ltd, Jluckiy, Fighty, Ryawan, NOMENI, DDgui, Fnochy Co.Ltd, qipopiq, HLKJKLS, AZZAKVG, Mocelyn, augper, ELLA A, Mango Mall, RENSHI, JIANLANJIAFANG, DingLi Fashion, Room Decor sign, Home garden decoration and Home Furnishing Materials added to case caption. (Text entry; no document attached.)

NEW PARTIES: Personalized wall plate, wudijunyishangmao, yuxingjing, Nokopwiuv, xujing3404, putianshilichengqugulariyongpindian, CHENXIANGGUIMAIYIFU, zzdlileshangmao, ngzhoufengxiangshangmaoyou, kantcute, bdywuno, weifangqianyidianzishangmaoyouxiangongsi, hausgd, hefeifengmingdianzishangwuyouxiangongsi, jhkhk, zhangzhichengcheng, panlongqusichaobaihuoshanghang, Defendant No. 18, rui shop, xwrggf, sujubaihuoxiaoshou, XTYKongHu, epengshangmao, baodingkuikuwenhuachuanboyouxiangongsi, kunmingaoxuanshangmaoyouxiangongsi, KE brant, ingtongguanshangmaoyo, SuLianShangMao126, xiangyangshixiangchezhuyuanshangmaoyouxiangongsi, cqxly, miaomansenstore, denwcsg, yxxi sp, mmie, Defendant No. 35, zhoutonghanshangm, Tibetan Spring, huanfu4060, SenTongShangMao, BZSXXDZSWYXGS, yangxiaolongzhixiaoyinshangmao and SenNanShangMao559 added to case caption. (Text entry; no document attached.)

MOTION by Plaintiff Jennifer Lambein for default judgment as to Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Jennifer Lambein in support of motion for default judgment[33]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[33] before Honorable Manish S. Shah on 9/17/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing on 9/17/24 is stricken. Judge Shah is not hearing motions the week of 9/16/24. Notices mailed.

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[33] before Honorable Manish S. Shah on 9/24/2024 at 09:45 AM.

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment[33] before Honorable Manish S. Shah on 9/24/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment [33] is granted. Enter Default Judgment Order. Civil case terminated. Notices Mailed.

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 9/24/2024. Notices Mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 2 wudijunyishangmao and no. 35

SATISFACTION of Judgment as to Defendant no. 195 RENSHI and no. 3 yuxingjing

SATISFACTION of Judgment as to Defendant no. 196 JIANLANJIAFANG

SATISFACTION of Judgment as to Defendant no. 193 ELLA A and no. 200 Home Furnishing Materials

SATISFACTION of Judgment as to Defendant no. 174 painting by numbers