2024-cv-07424

COMPLAINT filed by Chapter 4 Corp.; Filing fee $ 405, receipt number AILNDC-22377937.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Schedule A regarding complaint, [1]

MOTION by Plaintiff Chapter 4 Corp. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chapter 4 Corp.

Notice of Claims Involving Trademarks by Chapter 4 Corp.

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Quinn Bradley Guillermo

ATTORNEY Appearance for Plaintiff Chapter 4 Corp. by Luana Faria De Souza (Faria De Souza, Luana)

CASE ASSIGNED to the Honorable Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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 Chapter 4 Corp. for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Chapter 4 Corp. 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 Lisa M. Willis regarding memorandum in support of motion[12]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

SEALED EXHIBIT by Plaintiff Chapter 4 Corp. Exhibit 7 Parts 1-2 regarding declaration[14]

MOTION by Plaintiff Chapter 4 Corp. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Chapter 4 Corp. in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

Exhibit 1

Exhibit 2

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Motion for leave to file under seal [3] is granted. Plaintiff's Ex Parte Motion for entry of a Temporary Restraining Order [11] is granted. Plaintiff's motion for electronic service of process [16] is granted. Order to enter. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Rebecca R. Pallmeyer on 8/20/2024

Registry Deposit Information Form by Chapter 4 Corp.

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

Surety BOND in the amount of $ 50,000 posted by Chapter 4 Corp. (Document not Imaged)

MOTION by Plaintiff Chapter 4 Corp. for extension of time of Temporary Restraining Order

MEMORANDUM by Chapter 4 Corp. in support of extension of time[25]

DECLARATION of Quinn B. Guillermo regarding memorandum in support of motion[26]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order 25 is granted. Order to enter. Mailed notice.

EXTENSION OF TEMPORARY RESTRAINING ORDER: The TRO shall be extended for a period of fourteen (14) days until September 17, 2024. See attached Order for further details. Signed by the Honorable Rebecca R. Pallmeyer on 8/29/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Chapter 4 Corp. as to a certain Defendant

MOTION by Plaintiff Chapter 4 Corp. for preliminary injunction

Exhibit A

MEMORANDUM by Chapter 4 Corp. in support of motion for preliminary injunction[31]

Declaration of Quinn B. Guillermo

Exhibit 1

SUMMONS Returned Executed by Chapter 4 Corp. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/12/2024, answer due 10/3/2024.

Declaration of Luana Faria de Souza

Exhibit A

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of a preliminary injunction [31] is granted. Order to enter. The Law Firm of Greer, Burns & Crain, Ltd. is ordered to add all defendant names listed in 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. Mailed notice.

NEW PARTIES: Dongguan Caihe Printing Co., Ltd., Dongguan Jinchen Luggage Co., Ltd., Dongguan Langming Intelligent Technology Co., Ltd., Guangzhou Unimor Technology Co., Ltd., Haina Electronic Technology (dongguan) Co., Ltd., Huizhou Qianyu Jewelry Co., Ltd., Ningbo Xingchi Trading Co., Ltd., Quanzhou Anbu Trade Co., Ltd., Quanzhou Maoer Trading Co., Ltd., Quanzhou Zhongyu Footwear Co., Ltd., Shanghai Leibai Printing Co., Ltd., Shanghai Stonedoing Industry Company Limited, Shenzhen Beikebei Technology Co., Ltd., Shenzhen Boda Technology Co., Ltd., Shenzhen Egrade Electronic Technology Co., Ltd., Shenzhen Huachen Trading Co., Ltd., Shenzhen Inno Technology Co., Ltd., Shenzhen Juchen Electronic Technology Co., Ltd., Shenzhen MCL Industry Limited, Shenzhen Mingruifeng Electronic Technology Co., Ltd., Shenzhen Miratech Co., Ltd., Shenzhen Sindo Technology Co., Ltd., Shenzhen Stamor Industrial Co.,ltd, Shenzhen Xing Heng Yue Technology Co., Ltd., Shenzhen Xinqi Technology Co., Ltd., Shenzhen YLW Technology Co.,ltd, Tianjin LH Technology Co., Ltd., Yangzhou Mova Toys Trade Co., Ltd., Yiwu Xinxing Jewelry Co., Ltd., Zhanjiang Chikan District Xiaohua Advertising Business Department, A2P4E0DX7HFX00, chaofaoshop, Cingk, jia zhi xuan, Joe star - department store boutiques, Kakuoyilei, LinLi Art, Musou, Nw lzx, xldrypd, aixunbo, allyaccessory, asc-4884, blueplanetsol71, elroy_faulkner, hkgz13, in-public, KOK STICKERS, lightinthebox-0109, lightinthebox-0403, lightinthebox-0504, lightinthebox-0601, lightinthebox-0803, qinhaoy, shizi015, tateji0321, tulelet, y-bombbas, amelia_lia_la, siennakicks, naxienian, oilvuth, owreplica.com, supremestoredeutschland.com, supremeofficials.com, supremestore-us.com and supremejapanshop.com added to case caption.

PRELIMINARY INJUNCTION Order signed by the Honorable Rebecca R. Pallmeyer on 9/12/2024. Mailed notice

NOTICE of Voluntary Dismissal by Chapter 4 Corp. as to certain defendant

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff is directed to submit a written status report by 12/9/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Chapter 4 Corp. as to certain defendants

NOTICE of Voluntary Dismissal by Chapter 4 Corp. as to certain defendants

MOTION by Plaintiff Chapter 4 Corp. for entry of default, MOTION by Plaintiff Chapter 4 Corp. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Chapter 4 Corp. in support of motion for entry of default, motion for default judgment 40

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

(Exhibit 1)

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of default and default judgment 40 is granted. Final Judgment Order to enter. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 10/7/2024. Mailed notice.

NOTICE of withdrawal of surety bond 24 by John Summerfield (Received at the Intake Counter on 10/29/2024) (Received for docketing 11/21/2024)

FULL SATISFACTION of Judgment regarding order 44 in the amount of $500,000 as to certain defendants