2024-cv-07704

COMPLAINT filed by Dorna Sports, S.L.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22405412.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Dorna Sports, S.L. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Dorna Sports, S.L. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Dorna Sports, S.L. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Dorna Sports, S.L. by John Wilson

MOTION by Plaintiff Dorna Sports, S.L. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Dorna Sports, S.L.

CASE ASSIGNED to the Honorable Sara L. Ellis. Designated as Magistrate Judge the Honorable Maria Valdez. 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 Dorna Sports, S.L. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Dorna Sports, S.L. for temporary restraining order Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication

MEMORANDUM by Dorna Sports, S.L. in support of motion for temporary restraining order, 11

Declaration Orozco Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 1 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 2 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 3 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 4 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 5 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 6 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 7 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 8 of Orozco Declaration

SEALED DOCUMENT by Plaintiff Dorna Sports, S.L. Exhibit 2 Part 9 of Orozco Declaration

Notice of Claims Involving Trademarks by Dorna Sports, S.L.

NOTICE of Motion by Michael A. Hierl for presentment of motion for leave to file excess pages 10, motion for temporary restraining order, 11, motion to seal document 7 before Honorable Sara L. Ellis on 9/3/2024 at 09:45 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motions for leave to file under seal 7, for leave to file excess pages 10, and for entry of a temporary restraining order 11. The Court sets a telephonic status date for 9/17/2024 at 9:45 AM. Plaintiff should file any motion for preliminary injunction and notice it for presentment at the next status hearing. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Sara L. Ellis on 8/29/2024

MOTION by Plaintiff Dorna Sports, S.L. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 28 before Honorable Sara L. Ellis on 9/12/2024 at 01:45 PM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for extension of the temporary restraining order 28. The Court extends the TRO through 9/26/2024. The Court strikes the telephonic status date set for 9/17/2024 and resets it to 9/26/2024 at 1:45 PM. Plaintiff should file any motion for preliminary injunction and notice the motion for presentment at the next status date. No appearance is required on 9/12/2024. Mailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Dorna Sports, S.L. (Document not imaged)

MOTION by Plaintiff Dorna Sports, S.L. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction Nunc Pro Tunc to September 26, 2024

MEMORANDUM by Dorna Sports, S.L. in support of motion for preliminary injunction 32

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 32

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 32 before Honorable Sara L. Ellis on 10/1/2024 at 09:45 AM.

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

MINUTE entry before the Honorable Sara L. Ellis: Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (866) 434-5269, Access Code: 8087837. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for preliminary injunction 32. The Court strikes the status date set for 9/26/2024 and resets it to 10/29/2024 at 9:45 AM. Plaintiff should file any motion for default and default judgment and notice it for presentment at the next status date. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Hughes Socol PIers Resnick & Dym 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. https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice

PRELIMINARY INJUNCTION Order signed by the Honorable Sara L. Ellis on 9/26/2024. Mailed notice

NOTICE of Voluntary Dismissal by Dorna Sports, S.L. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 208

ATTORNEY Appearance for Defendant Fullmosa US by Ruoting Men

NOTICE of Voluntary Dismissal by Dorna Sports, S.L. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendant Fullmosa US by Xionghui Murong

MOTION by Defendant Fullmosa US for extension of time to file response/reply as to complaint[1]

ATTORNEY Appearance for Defendant Fullmosa US by Tao Liu

SUMMONS Returned Executed by Dorna Sports, S.L. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 9/25/2024, answer due 10/16/2024.

CERTIFICATE of Service by John Wilson on behalf of Dorna Sports, S.L.

MOTION by Plaintiff Dorna Sports, S.L. for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

Exhibit A

MEMORANDUM by Dorna Sports, S.L. in support of motion for default judgment[47]

Exhibit 1

Exhibit 2

DECLARATION of Michael A. Hierl regarding motion for default judgment[47]

Exhibit Hierl Exhibit 1

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment[47] before Honorable Sara L. Ellis on 10/29/2024 at 09:45 AM.

NOTICE of Voluntary Dismissal by Dorna Sports, S.L. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for entry of default and default judgment [47]. The Court enters judgment in favor of Plaintiff and against Defendants identified on Amended Schedule A. Case terminated. Mailed notice

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Fullmosa US, MOTION by Defendant Fullmosa US to vacate preliminary injunction[38]

Exhibit Email - Men, Ruoting -

Exhibit Evidence Fullmosa US

Declaration Decl. of KAIQIANG SHI

NOTICE of Motion by Ruoting Men for presentment of Motion to Dismiss for Failure to State a Claim, motion to vacate, [53] before Honorable Sara L. Ellis on 11/7/2024 at 01:30 PM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Defendant's motion for extension of time to answer or otherwise plead [43]. Defendant's responsive pleading is due by 10/30/2024. The Court sets the following briefing schedule on Defendant's motion to dismiss and to vacate the preliminary injunction [53]: Plaintiff's response is due by 12/6/2024 and Defendant's reply is due by 12/20/2024. The Court reopens this case. The Court sets a ruling date for 3/12/2025 at 9:30 AM. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

MOTION by Defendant Fullmosa US to set a briefing schedule SHORTEN TIME FOR BRIEFING AND HEARING

NOTICE of Motion by Ruoting Men for presentment of motion by filer to set a briefing schedule[56] before Honorable Sara L. Ellis on 11/12/2024 at 09:30 AM.

NOTICE of Voluntary Dismissal by Dorna Sports, S.L. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 226

MINUTE entry before the Honorable Sara L. Ellis: Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

NOTICE of Voluntary Dismissal by Dorna Sports, S.L. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Sara L. Ellis:Telephone conference held on 11/12/2024 as to motion by filer to shorten briefing schedule [56] and continued to 11/14/2024 at 1:45 PM. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Sara L. Ellis on 11/13/2024:Emailed notice

MOTION by Plaintiff Dorna Sports, S.L. Joint Motion for Entry of an Agreed Asset Restraint Order

MINUTE entry before the Honorable Sara L. Ellis: Telephonic motion hearing held on 11/14/2024. Defendant's motion to shorten time for briefing and hearing [56] is denied. Joint motion for entry of an agreed asset restraint order [63] is granted. The Court sets ruling date for 3/12/2025 at 9:30 a.m. for ruling on motion to dismiss or alternatively motion to vacate preliminary injunction [53]. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

AGREED ASSET RESTRAINT ORDER. Signed by the Honorable Sara L. Ellis on 11/19/2024:Emailed notice

MAILED original ten-thousand-dollar $10,000 surety bond posted by Dorna Sports, S.L. to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602 via certified mail #9589 0710 5270 0579 7825 64

MOTION by Plaintiff Dorna Sports, S.L. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

RESPONSE by Plaintiff Dorna Sports, S.L. Plaintiff's Response to the Motion to Dismiss by Defendant No. 246 "Fullmosa US" [Dkt. No. 53]

Exhibit A

Exhibit B

Exhibit C

Exhibit D

NOTICE of Motion by Michael A. Hierl for presentment of motion for leave to file excess pages[66] before Honorable Sara L. Ellis on 12/10/2024 at 09:45 AM.

MINUTE entry before the Honorable Sara L. Ellis: The Court grants Plaintiff's motion for leave to file excess pages [66]. Plaintiff's response may be up to 17 pages. Emailed notice

RETURN of U.S. Post of Reciept, certified number 9589 0710 5270 0579 7825 64 executed on 12/12/24. (Received by Clerk's Office Mail Room on 12/17/24).

MOTION by Defendant Fullmosa US to withdraw Motion to Dismiss for Failure to State a Claim, motion to vacate, [53]

NOTICE of Motion by Ruoting Men for presentment of motion to withdraw[71] before Honorable Sara L. Ellis on 1/7/2025 at 09:45 AM.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

SATISFACTION of Judgment

MINUTE entry before the Honorable Sara L. Ellis: : The Court grants Defendant's motion to withdraw its motion to dismiss [71]. The Court strikes Defendant's motion to dismiss [53] and attendant briefing schedule and ruling date set for 3/12/2025. The Court sets a status date for 1/21/2025 at 9:30 AM. If the parties file a stipulation of dismissal prior to the next status date, no appearance is required. Attorneys/Parties should appear for the hearing by calling the Toll-Free Number: (650) 479-3207, Access Code: 2314 361 1508. Throughout the telephonic hearing, each speaker will be expected to identify themselves for the record before speaking. Please note that the conference call-in will be used by all cases that are on the court's calendar for the said date, therefore counsel must be in a quiet area while on the line and must have the telephone muted until your case is called. Members of the public and media will be able to call in to listen to this hearing (use toll-free number). Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Emailed notice

STIPULATION of Dismissal Stipulation of Voluntary Dismissal with Prejudice

MINUTE entry before the Honorable Sara L. Ellis: Telephone conference held on 1/21/2025. Pursuant to stipulation of voluntary dismissal with prejudice 76, this case is dismissed with prejudice. Each party shall bear its own attorney's fees and costs. Civil case terminated. Emailed notice

SATISFACTION of Judgment