2024-cv-08087

COMPLAINT filed by Hainan Changyuan Technology Co. Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22440684.

ATTORNEY Appearance for Plaintiff Hainan Changyuan Technology Co. Ltd. by Robert Michael Dewitty

CIVIL Cover Sheet

Exhibit A by Hainan Changyuan Technology Co. Ltd. accompanying complaint

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. to seal Schedule A and Exhibit B

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. to seal Memorandum in support thereof

EXHIBIT B by Plaintiff Hainan Changyuan Technology Co. Ltd. Modified on 10/10/2024.

SCHEDULE A by Plaintiff Hainan Changyuan Technology Co. Ltd. Modified on 10/10/2024.

CASE ASSIGNED to the Honorable Sunil R. Harjani. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment. (Civil Category 2). (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 trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

SEALED DOCUMENT by Plaintiff Hainan Changyuan Technology Co. Ltd. updated Exhibit B

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for temporary restraining order

(Declaration Declaration of Robert M. DeWitty)

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for temporary restraining order Memorandum in support thereof

EXHIBIT 1 by Plaintiff Hainan Changyuan Technology Co. Ltd. Exhibit 1 in support of TRO Modified on 10/10/2024.

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion to file under seal 5 and ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and publication 12 are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit products, and 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 effectively communicates the pendency of this action to defendants. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) if appropriate no later than 9/18/2024. Telephone status hearing is set for 9/25/2024 at 9:15 a.m. By 9/11/2024, Plaintiff shall submit a proposed temporary restraining order to the Court's proposed order inbox for entry. The Court presumptively requires a bond of $1,000 per defendant. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Enter Sealed Temporary Restraining Order at 10:00 a.m. on 9/13/2024. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Sunil R. Harjani on 9/13/2024. Mailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified in Schedule A (Text entry; no document attached.)

MINUTE entry before the Honorable Sunil R. Harjani: At counsel's request, telephone status previously set for 9/25/2024 is reset to 9/24/2024 at 9:15 a.m. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

SURETY BOND in the amount of $ 32,000 posted by Hainan Changyuan Technology Co. Ltd. (Document not scanned)

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for extension of time Motion to Extend the Temporary Restraining Order

SUBMISSION of Bond in Response to TRO. (Received at the Intake Counter on 9/18/2024)

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's Motion to Extend the Temporary Restraining Order 20 is granted. For the reasons stated in Plaintiff's Motion, the Court finds good cause to extend the temporary restraining order an additional 14 days to 10/9/2024. Plaintiff shall file a preliminary injunction motion if appropriate no later than 10/2/2024. Telephone status hearing set for 9/24/2024 is stricken and reset to 10/9/2024 at 9:15 a.m. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: At counsel's request, telephone status set for 10/9/2024 is reset to 10/8/2024 at 9:15 a.m. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

SUMMONS Returned Executed by Hainan Changyuan Technology Co. Ltd. as to The Partnerships and Unincorporated Associations Identified in Schedule A on 10/2/2021, answer due 10/23/2021.

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for preliminary injunction on Defendants in Schedule A

Memorandum in support of Motion for Preliminary Injunction of Defendants in Schedule A by Hainan Changyuan Technology Co. Ltd.

(Exhibit Case law)

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion 25 for entry of a preliminary injunction. In connection with that motion, plaintiff must serve all defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by 10/7/2024." If no objections are filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 10/7/2024. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. Telephone status hearing set for 10/8/2024 at 9:15 a.m. is stricken. Mailed notice

ATTORNEY Appearance for Defendants RIDGE WASHER, JoeJet by Adam Edward Urbanczyk

CERTIFICATE of Service by Plaintiff Hainan Changyuan Technology Co. Ltd. regarding terminate hearings, 27 service of Defendants listed in Schedule A

(Exhibit 1 - Email)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Def No 2 of Schedule A

MOTION by Defendants JoeJet, RIDGE WASHER to set a briefing schedule re: [Dkt 25] and Unseal [Dkts. 7-8, 14]

MINUTE entry before the Honorable Sunil R. Harjani: Certain Defendants' Motion to Set Briefing Schedule and to Unseal 31 does not indicate whether there is an objection to the motion. Counsel shall meet and confer concerning the motion. By 10/8/2024, the parties shall file a joint status report advising whether or not the motion is agreed and if agreement cannot be reached, the basis of Plaintiff's objection. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: The following order does not apply to Defendants JoeJet and RIDGE WASHER. Plaintiff's motion for a preliminary injunction 25 is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established [24, 29] that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents. Summons was issued on 9/17/2024, and Defendants' responses to the complaint are due by 10/23/2024. Plaintiff should file any motion for entry of default and default judgment by 11/13/2024. If there are any remaining defendants whom default and default judgment are not being sought, Plaintiff is ordered to file a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. A telephone status hearing is set for 11/21/2024 at 9:15 a.m. By 10/9/2024, Plaintiff shall submit a proposed preliminary injunction order to the Court's proposed order inbox for entry. Mailed notice

STATUS Report JOINT by JoeJet, RIDGE WASHER

MINUTE entry before the Honorable Sunil R. Harjani: The Motion to Set Briefing Schedule and to Unseal 31 is granted as unopposed. The Clerk is requested to unseal Dkts. 7-8 and 14. Defendants RIDGE WASHER and Joejet have until 10/14/2024 to respond to Plaintiff's motion for preliminary injunction [Dkt. 25] and Plaintiff may reply by 10/21/2024. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Sunil R. Harjani on 10/10/2024. Mailed notice

NEW PARTIES: AJF Forever, Daji-Direct, duzforei, hanyunpeiyuanmaoyi, Hoypeyfiy, JoeJet, Moaode-EU, Niuliy, S T Sales Inc, ShadowY, Wansu-Direct, touyoo, Wansu-Direct, YBJ-US, Tzgsonp, Jariko, MINGLE Tool, ktopnob, Saiper, Altima-Store, JZ Racing Performance, best online-store, Southeast Softwash, Slowirrigate, ZHIXING-US, TADYAO, Dongguan Fengyun Spray Technology Development Co., Ltd., Guangdong Boyuan Spraying Technology Co., Ltd., Guizhou Blue Whale Machinery Equipment Co., Ltd., Jinhua Fenjun Industry And Trade Co.,Ltd, Shandong Yatemei Environmental Technology Co., Ltd., Taizhou Juxing Technology Co., Ltd., WAWULUGALA ENGINEERS (PRIVATE) LIMITED, Zhuji Yujia Environmental Protection Technology Co., Ltd., Korea Trendy Apparel Store and FIBO Official Store added to case caption. Terminating The Partnerships and Unincorporated Associations Identified in Schedule A (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Defendant #11 from Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Defendant #13 from Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Defendant #19 from Schedule A

RESPONSE by Defendants RIDGE WASHER, JoeJet to other 26

(Declaration of Jie Fang)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. No. 11 in Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. No. 13 of Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. No. 31 of Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. No. 19 of Schedule A

REPLY by Hainan Changyuan Technology Co. Ltd. to Response 40

Exhibit Exhibit A

Exhibit Exhibit B

Exhibit Exhibit C

Exhibit Exhibit D

(Exhibit Exhibit E)

MINUTE entry before the Honorable Sunil R. Harjani: In-person motion hearing on Defendants RIDGE WASHER and JoeJet's opposition to Plaintiff's motion for entry of preliminary injunction 40 set for 11/6/2024 at 9:30 a.m. in Courtroom 1925. Mailed notice Modified on 10/23/2024.

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of No. 32 in Schedule A

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of No. 16 in Schedule A

NEW PARTIES: Mebon Tech (Seller ID: A2IMW7TM5DYHI1) added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Sunil R. Harjani: In-person motion hearing on Defendants RIDGE WASHER and JoeJet's opposition to Plaintiff's motion for entry of preliminary injunction 40 is reset to 11/12/2024 at 9:45 a.m. in Courtroom 1925. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Mebon Tech (No. 8)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of hanyunpeiyuanmaoyi (No. 5 in Schedule A)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Niuliy (No. 10 on Schedule A)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of touyoo (No. 16 of Schedule A)

ATTORNEY Appearance for Defendant MINGLE Tool by Adam Edward Urbanczyk

MOTION by Defendant MINGLE Tool to vacate preliminary injunction 36

(Declaration of Jie Fang)

ATTORNEY Appearance for Defendant Slowirrigate by Christopher Paul Keleher

MOTION by Defendant Slowirrigate for extension of time to file answer regarding complaint 1 (UNOPPOSED)

MINUTE entry before the Honorable Sunil R. Harjani: Status hearing held. Plaintiff's motion for preliminary injunction as to Defendants JoeJet and Ridge Washer 25 is fully briefed and the Court will issue a written ruling. Plaintiff's response to Defendant Mingle Tool's motion to vacate preliminary injunction 55 is due 11/22/2024; Defendant Mingle Tool's reply is due 12/6/2024. As discussed in open court, the parties are directed to meet and confer in good faith in an attempt to reach an agreement. Status hearing set for 12/17/2024 at 9:15 a.m. by telephone. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Defendant Slowirrigate (A24YOARWK0DOVG)'s unopposed first motion for extension to time to answer or otherwise plead 57 is granted. Defendant Slowirrigate (A24YOARWK0DOVG) shall answer or otherwise respond to the complaint by 12/3/2024. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff did not file the status report due 11/13/2024. See Doc. 33. By 11/25/2024, Plaintiff shall file a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Saiper (No. 23 of Schedule A)

STATUS Report by Hainan Changyuan Technology Co. Ltd.

(Exhibit)

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed Plaintiff's Status Report 62 and spreadsheet 63. Any motion for default and default judgment is due by 12/3/2024. Plaintiff shall also file the notices of voluntary dismissal as to the parties listed in the spreadsheet to be dismissed without prejudice by 12/3/2024. As to the parties where settlement is anticipated, a notice of voluntary dismissal or joint stipulation to dismiss is due by 12/10/2024. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Defendant Hoypeyfiy (#6 on Schedule A)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Defendant Duzforei~ (#4 of Schedule A)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of JZ Racing Performance (#25 of Schedule A)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of JZ Racing Performance (No. 25 of Schedule A)

REQUEST For Default summons returned executed 24 Default and Default Judgment against the Defaulting Defendants (EX. 1)

Exhibit (Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30)

(Declaration of Robert Dewitty)

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for default judgment as to Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30

Exhibit 1 (Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30)

(Declaration of Robert Dewitty)

MEMORANDUM by Hainan Changyuan Technology Co. Ltd. in support of motion for default judgment, 69 for Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30

(Exhibit 1 (Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30))

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion 69 for entry of default and default judgment against Defendant Nos. 13, 14, 20, 21, 22, 24, 27, 29, 30. Defendant Nos. 13, 14, 20, 21, 22, 24, 27, 29, 30 have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 12/11/2024. If no objections are filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 12/11/2024. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon Defendant Nos. 13, 14, 20, 21, 22, 24, 27, 29, 30 within one business day of its entry on the docket and must promptly file proof of that service. A tentative default judgment hearing is set for 12/18/2024 at 9:15 a.m. Mailed notice

ANSWER to Complaint, COUNTERCLAIM filed by RIDGE WASHER, JoeJet, MINGLE Tool against Hainan Changyuan Technology Co. Ltd. by RIDGE WASHER, JoeJet, MINGLE Tool

Exhibit 1

(Exhibit 2)

OBJECTIONS by MINGLE Tool, RIDGE WASHER, JoeJet to MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for default judgment as to Def Nos: 13, 14, 20, 21, 22, 24, 27, 29, 30 69

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff did not file a response to Defendant MINGLE Tool's motion to vacate the preliminary injunction and the time for doing so has passed. See Doc 58. Accordingly, Defendant MINGLE Tool's motion to vacate the preliminary injunction 55 is granted as unopposed. For the reasons stated in Defendants RIDGE WASHER, JoeJet, and MINGLE Tool's Objection to Entry of Default and Default Judgment 73, the entry of default as to Defendant MINGLE Tool is vacated and Defendants RIDGE WASHER, JoeJet, and MINGLE Tool's request to file a late answer and counterclaim is granted 72. Mailed notice.

MOTION by Defendant Slowirrigate for extension of time to file answer regarding complaint 1 (UNKNOWN IF OPPOSED)

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is Defendant Slowirrigate's Second Motion for Extension to Time 75 to respond to the complaint. The motion does not state whether Plaintiff opposes the requested relief, as required by the Court's Standing Order Re Civil Motion Practice (available on the Court's web page). Accordingly, the motion 75 is denied without prejudice to refiling with the required statement indicating whether there is an objection to the motion. If the motion is opposed, Defendant must include a statement from Plaintiff indicating the specific grounds for the objection. Mailed notice

MOTION by Defendant Slowirrigate for extension of time to file answer (AGREED)

MINUTE entry before the Honorable Sunil R. Harjani: Defendant Slowirrigate's agreed second motion for extension of time to answer or otherwise plead 77 is granted to allow the parties to exhaust settlement negotiations. Defendant Slowirrigate is to respond to the complaint by 12/31/2024. Mailed notice

STATUS Report by Hainan Changyuan Technology Co. Ltd.

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed Plaintiff's latest status report 79 regarding Defendant Nos. 28, 26, 6, 25, and 23. As to Defendant No. 23, a notice of voluntary dismissal or joint stipulation to dismiss is due by 12/18/2024. Regarding Defendant Nos. 26, and 28, a status report with an update on settlement negotiations is due by 12/18/2024. By 12/16/2024, Plaintiff and Defendants RIDGE WASHER, JoeJet, and MINGLE Tool shall file a joint initial status report. A template for the Joint Initial Status Report can be found on the court's web page. Telephone status hearing set for 12/17/2024 at 9:15 a.m. stands. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Regarding plaintiff's motion for default and default judgment 69, plaintiff did not file proof of notice to defendants of the objection deadline as required by the Court's Order dated 12/4/2024. See Doc. 71. By the close of business on 12/13/2024, plaintiff's counsel shall file a status report advising whether he timely served the Court's Order dated 12/4/2024 on the defaulting defendants by 12/5/2024. Mailed notice

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for extension of time to Reset Dates on Plaintiff's Motion for Default

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's Request to Reset Dates on Plaintiff's Motion for Default 82 is granted as follows. An order of default has been entered against Defendant Nos. 13, 14, 20, 22, 24, 27, 29, 30 under Rule 55(a) of the Federal Rules of Civil Procedure. See Doc. 71. Any objections to the motion for entry of default judgment must be filed on or before 12/19/2024. If no objections are filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 12/19/2024. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing as a separate entry on the docket. Plaintiff must serve this minute order upon Defendant Nos. 13, 14, 20, 22, 24, 27, 29, 30 within one business day of its entry on the docket and must promptly file proof of that service. The tentative default judgment hearing set for 12/18/2024 at 9:15 a.m. is stricken and reset to 1/2/2025 at 9:15 a.m. Mailed notice

STATUS Report Initial Status Report by Hainan Changyuan Technology Co. Ltd.

ATTORNEY Appearance for Defendants MINGLE Tool, RIDGE WASHER, JoeJet by Brian Swift

MINUTE entry before the Honorable Sunil R. Harjani: Telephonic status hearing held. In the Court's order entered on December 13, 2024, Plaintiff's counsel was directed to file a certificate of service on the docket with respect to their motion for default judgment, showing that Defendants have been served, which has not been completed. Plaintiff's counsel is directed to file the required certificate of service by the end of business today, Tuesday, December 17, 2024. Upon review of the Joint Initial Status Report 84, the Court sets the following schedule: (1) Rule 26(a)(1) initial disclosures to be provided by January 3, 2025; (2) Amendments of pleadings or joinder of other parties by April 3, 2025; (3) Written discovery requests to be issued by January 17, 2025; (4) Notices of depositions with agreed upon dates to be issued by April 18, 2025; (5) Rule 45 subpoenas to be issued by April 18, 2025; and (6) Fact discovery must be completed by June 6, 2025. No summary judgment motion may be filed until an in-person status conference has been held with the Court. With respect to any anticipated motion for summary judgment, the Court requires the moving party to file a status report addressing the applicable law and explaining in detail why there are no genuine issues of material fact and why the moving party is entitled to judgment as a matter of law. The moving party shall file the status report one week in advance of the in-person status conference. This case is referred to the Magistrate Judge for discovery supervision (including adjusting all deadlines as needed), resolution of discovery motions, and settlement discussions. An in-person status hearing is set for 6/12/2025 at 9:15 a.m. Mailed notice

ATTORNEY Appearance for Defendants AJF Forever, Daji-Direct, Moaode-EU, Wansu-Direct, YBJ-US by Christopher Paul Keleher

MOTION by Defendants AJF Forever, Daji-Direct, Moaode-EU, Wansu-Direct, YBJ-US to compel (OPPOSED)

CERTIFICATE of Service by Robert Michael Dewitty on behalf of Hainan Changyuan Technology Co. Ltd. regarding terminate hearings, set/reset hearings, 83

MINUTE entry before the Honorable Sunil R. Harjani: Opposed motion to compel 88 is set for 12/19/2024 at 2:00 p.m. by telephone. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

ATTORNEY Appearance for Defendants Jariko, ktopnob, Southeast Softwash by Adam Edward Urbanczyk

MOTION by Defendant Jariko to vacate the default order and stay the case pending resolution of the cancellation action filed with the USPTO. Modified on 12/18/2024.

Exhibit Dkt No. 71

(Exhibit Petition to cancel)

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed the Letter from Yaroslav Kolubai dated 12/18/2024 regarding Defendant Jariko (No. 20). The Court construes the letter as a motion to vacate the default order and stay the case pending resolution of the cancellation action filed with the USPTO. The Clerk is directed to file Mr. Kolubai's letter as a motion on the docket. Hearing regarding Defendant Jariko's motion is set for 1/8/2025 at 9:45 a.m. by telephone. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

STATUS Report Defs. 26 and 28 by Hainan Changyuan Technology Co. Ltd.

MINUTE entry before the Executive Committee: CASE REFERRED to Magistrate Judge Honorable Keri L. Holleb Hotaling 72.1. Mailed notice

(Request for Reassignment)

MINUTE entry before the Honorable Sunil R. Harjani: The Court has reviewed Plaintiff's latest status report 94 regarding Defendant Nos. 26 and 28. Plaintiff's notices of voluntary dismissal as to Defendant Nos. 26 and 28 shall be filed by 12/24/2024. Mailed notice

MOTION by Defendants Jariko, ktopnob, Southeast Softwash to vacate R. 55(a) default Presented before District Judge

Declaration of Yaroslav Kolubai

Declaration of Roman Ratniuk

(Declaration of Coty Yarbrough)

ANSWER to Complaint, COUNTERCLAIM filed by Southeast Softwash, Jariko, ktopnob against Hainan Changyuan Technology Co. Ltd. by Southeast Softwash, Jariko, ktopnob

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Sunil R. Harjani: Telephonic motion hearing held on 12/19/2024. Plaintiff's counsel failed to appear. Defendants AJF Forever, Daji-Direct, Moaode-EU, Wansu-Direct, YBJ-US's opposed motion to compel 88 is granted. Defendants AJF Forever, Daji-Direct, Moaode-EU, Wansu-Direct, YBJ-US are dismissed without prejudice that will convert to with prejudice in 30 days. If Plaintiff's counsel fails to appear at the next hearing, then the entire case will be dismissed for want of prosecution. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Defendants' motion to set aside clerk's entry of default and objection to entry of default 97 is set for 1/8/2025 at 9:30 a.m. by telephone. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Defendant Nos. 13, 14, 24, 29, and 30 have not responded to plaintiff's motion for entry of default judgment. Accordingly, the motion 69 is granted as to Defendant Nos. 13, 14, 24, 29, and 30. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's mark irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the Court concludes that $30,000 is an appropriate award of statutory damages. Plaintiff has also certified and established 89 that it provided electronic notice to defendants of the objection deadline, but no objection to the motion for entry of default judgment has been filed on behalf of Defendant Nos. 13, 14, 24, 29, and 30. Because no default judgment hearing has been requested, the default judgment hearing tentatively set for 1/2/2025 is stricken. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any defendant. By the close of business on 12/23/2024, Plaintiff shall submit a proposed default judgment order to the Court's proposed order inbox for entry. Plaintiff's motion for default judgment is entered and continued as to Defendant Nos. 20, 22, and 27. Mailed notice

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter has been referred to Judge Holleb Hotaling for discovery management and settlement. By 1/27/2025, the parties are to file their initial Rule 26(f) conference report which shall, inter alia, propose a fact discovery schedule, indicate whether the parties have already engaged in any settlement discussions and the general nature of those discussions, and include a statement on whether (and which of) the parties are interested in a settlement conference at this juncture.

MINUTE entry before the Honorable Sunil R. Harjani: Enter Final Default Judgment Order as to Defendant Nos. 13, 14, 24, 29, and 30. Emailed notice

FINAL DEFAULT JUDGMENT ORDER signed by the Honorable Sunil R. Harjani on 12/26/2024. Emailed notice

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.

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd.

MOTION by Defendant MINGLE Tool to compel notice of Amazon.com re: Dkt. 74 Presented before District Judge

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MINUTE entry before the Honorable Sunil R. Harjani: Defendants' motion to compel notice [107] is set for 1/8/2025 at 9:45 a.m. by telephone. MOTION by Defendants Jariko, ktopnob, Southeast Softwash to vacate R. 55(a) default [97] set for 1/8/2025 is amended to begin at 9:45 a.m. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Jariko (No, 20)

MINUTE entry before the Honorable Sunil R. Harjani: Telephonic motion hearing held. Counsel for Plaintiff and Defendants Ridge Washer, JoeJet, MINGLE Tool, Jariko, Ktopnob, Southeast Softwash were present. Without objection and for the reasons stated on the record, Defendant MINGLE Tool's motion to compel notice as to Amazon [107] and Defendants' motion to vacate rule 55(a) default [97] are granted. Plaintiff is directed to notify Amazon that the restraints on Defendant MINGLE Tool, Amazon seller ID A124UZQ9TIB6CO be lifted. Rule 55 default entered on 12/13/2024 [83] is hereby vacated as to Ktopnob and Southeast Southwash defendants. In light of the Notice of Voluntary Dismissal [109], Defendant Jariko (Defendant No. 20) with Amazon seller ID no. A3L53D36YHWDDZ, identified in Schedule A of the Complaint have reached an agreement and Defendant Jariko is hereby dismissed with prejudice. Each side shall bear its own fees, costs, and expenses. Plaintiff and Defendants Ktopnob and Souteast Southwash shall proceed with the discovery schedule [86] entered on 12/17/2024. Counsel may reach out to Magistrate Judge Holleb Hotaling for assistance with settlement discussions. Should an agreement be reached, counsel may file a notice of voluntary dismissal. In-person status hearing set for 6/12/2025 at 9:15 a.m. [86], stands. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Pl's motion for default judgment as to Defendant Nos. 20 (Jariko), 22 (Ktopnob), and 27 (Southeast Softwash) [69], which was entered and continued on 12/20/2024, is denied as moot. See Doc. 101. Plaintiff has not filed the notices of voluntary dismissal as to Defendant Nos. 26 (best online-store) and 28 (Slowirrigate) which were due by 12/24/2024. See Doc. 96. Plaintiff shall the notices of voluntary dismissal as to Defendant Nos. 26 (best online-store) and 28 (Slowirrigate) by 1/13/2025. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of best-online store (Def 26)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Slowirrigate (Def No. 28)

REPORT of Rule 26(f) Planning Meeting by Hainan Changyuan Technology Co. Ltd.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The Court is in receipt of the parties' report of their Rule 26(f) planning meeting Dkt. [114]. The Court adopts the following dates: the deadline for amendments to pleadings and/or addition of parties is 3/31/2025; Rule 26(a)(1) disclosures shall be made by 2/14/2025; the firm fact discovery deadline is 6/14/2025. Although the parties anticipate expert discovery, the Court will not set an expert discovery schedule until it is clear the fact discovery deadline will be met. The parties are reminded to promptly bring any discovery motions before the Court, including motions to enforce subpoenas or motions for protective orders. The parties report they have engaged in settlement discussions, but have reached an impasse; they do not request a settlement conference at this time. The parties are to file an updated joint status report on 3/31/2025 detailing the progress of fact discovery and indicating whether they are interested in a settlement conference at that juncture. The parties should keep in mind that Judge Holleb Hotaling's schedule typically is booked 2-3 months out from present with regards to settlement conferences, so the parties should notify Judge Holleb Hotaling's chambers as soon as possible once they realize they want a settlement conference; they do not need to wait for a status report date. Mailed notice.

PRO SE Appearance by Defendant Michael Moon (Received via PDF Submission link on Box.com on 02/19/25)

DECLARATION of Michael Moon (Received via PDF Submission link on Box.com on 02/19/25)

RESPONSE by Defendant S T Sales Inc in opposition to plaintiff's motion for entry of preliminary injunction (Received via PDF Submission link on Box.com on 02/19/25)

MINUTE entry before the Honorable Sunil R. Harjani: Telephone status hearing regarding Defendant S T Sales Inc's Response in Opposition to Plaintiff's Motion for Entry of Preliminary Injunction [118] set for 3/12/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of Ktnob (Def. No. 22)

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of ZHIXING-US (Def. No 29)

MINUTE entry before the Honorable Sunil R. Harjani: Telephonic status hearing held. Defendant Michael Moon and Counsel Brian Swift, representing a group of six defendants, including Joe Jet and Southeast Softwash, were present. Plaintiffs' counsel, Robert Dewitty, failed to appear or notify the Court regarding any scheduling conflict. Hearing on Defendant Moon's opposition to preliminary injunction [118] is reset to 4/2/2025 at 9:15 a.m. by telephone. Plaintiff's counsel is ordered to appear at the next hearing or this case will be dismissed for want of prosecution. Plaintiff's counsel is also encouraged to reach out to Defendant Moon and attempt to resolve this matter before the next hearing. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The parties failed to file their 3/31/2025 joint status report as ordered [Dkt. 115]. The parties are to file that joint status report by 4/8/2025 with an explanation for its tardiness.

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. S T Sales

MINUTE entry before the Honorable Sunil R. Harjani: Telephonic motion hearing held on 4/2/2025. As stated on the record, Plaintiff's oral motion to vacate the preliminary injunction and default judgment against defendant ST Sales is granted, and as a result of plaintiff's counsel's representation, ST Sales is voluntarily dismissed from this case as a defendant. The injunction against ST Sales is also lifted. Plaintiff's counsel was ordered to communicate with counsel for the remaining defendants after this hearing, and attempt to resolve the entire case so that it may be terminated, as Plaintiff's counsel represented that the case would likely be settled or dismissed against any defendant remaining. Mailed notice.

STATUS Report JOINT by JoeJet, MINGLE Tool, RIDGE WASHER, Southeast Softwash Presented before Magistrate Judge

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The parties' joint status report [Dkt. 126] indicates they are progressing smoothly with discovery with only minor hiccups in advance of the firm 6/14/2025 fact discovery deadline. The parties are reminded to promptly bring any discovery motions before the Court, including motions to enforce subpoenas or motions for protective orders. The parties are not interested in a settlement conference at this time. The parties should keep in mind that Judge Holleb Hotaling's schedule typically is booked 2-3 months out from present with regards to settlement conferences, so the parties should notify Judge Holleb Hotaling's chambers as soon as possible once they realize they want a settlement conference; they do not need to wait for the next status report date. The parties are to file an updated joint status report on 5/9/2025.

MOTION by Defendant Southeast Softwash to vacate preliminary injunction[36] Presented before District Judge

STATUS Report JOINT by JoeJet, MINGLE Tool, RIDGE WASHER, Southeast Softwash Presented before Magistrate Judge

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Upon review of the parties' joint status report [Dkt. 129], which indicates that Plaintiff has not provided Rule 26(a)(1) initial disclosures or responded to discovery requests propounded on January 18, 2025, the Court sets a telephonic status on 5/20/2025 at 10:00 a.m. Call-in information is: 855-244-8681, access code 2315 091 1461.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Telephonic status hearing held 5/20/2025. Plaintiff to file a stipulation of dismissal as to Defendant Southeast Softwash by 5/23/2025. A follow-up telephonic status hearing is set for 6/10/2025 at 10:00 a.m. to determine the next steps in this litigation. The call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

STIPULATION of Dismissal with Southeast Softwash

MINUTE entry before the Honorable Sunil R. Harjani: Based upon Plaintiff's notice of voluntary dismissal 132, this case is hereby dismissed with prejudice as to the following Defendant: Southeast Softwash. Each party shall bear its own attorney's fees and costs. Defendant Southeast Softwash's Motion to Vacate the Preliminary Injunction 128 is denied as moot. All pending deadlines, motions, and hearings related to this Defendant are stricken. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: In-person status hearing set for 6/12/2025 is stricken and reset to 6/26/2025 at 9:15 a.m. Mailed notice

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Plaintiff's counsel failed to appear for the telephonic status hearing scheduled for 6/10/2025 at 10:00 a.m. CT. Therefore, the status hearing in this matter is reset to an IN-PERSON status hearing on 6/24/2025 at 11:00 a.m. CT in Courtroom 1700, 219 South Dearborn Street, Chicago, IL 60604. If Plaintiff fails to appear, it risks adverse consequences in this litigation, including the Magistrate Judge recommending to the District Judge that Plaintiff's case be dismissed for lack of prosecution. Pro Se Defendant Michael Moon is given leave to appear telephonically at this hearing; the call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

MINUTE entry before the Honorable Sunil R. Harjani: In-person status hearing set for 6/26/2025 is stricken and reset to 7/22/2025 at 9:15 a.m. Mailed notice

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter was rescheduled to a 6/24/2025 IN-PERSON hearing because Plaintiff's counsel failed to appear at a prior telephonic hearing. Plaintiff's counsel again failed to appear at the 6/24/2025 hearing, despite being warned of the consequences [Dkt. 135]. Counsel for Defendants appeared and the case was called at 11:23 a.m., 23 minutes after the scheduled start time. Additionally, the Courtroom Deputy also telephoned Plaintiff's counsel's office from the Courtroom but Plaintiff's counsel could not be reached and his staff was not well-informed as to his whereabouts. (The Court notes it sat on the bench until 1:25 p.m. and counsel for Plaintiff still failed to appear, nor did anyone representing Plaintiff call Chambers.) Therefore, as forecast, Magistrate Judge Holleb Hotaling recommends to the District Judge that this case be dismissed for lack of prosecution. However, Defendants raised a concern that they may need a judgment on the merits in order unfreeze the assets/recoup costs subject to the TRO, but the Court advised that this is an issue for the District Judge. All upcoming dates before Judge Holleb Hotaling are stricken. The referral is closed and the case is returned to the assigned District Judge. Judge Holleb Hotaling no longer referred to this case.

RESPONSE by Plaintiff Hainan Changyuan Technology Co. Ltd. to terminate referral, set/clear flags, [137] to Minute Entry

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MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. to reset hearing 7/22 to week of 7/27

Exhibit A

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion to reset the status hearing 139 is granted. In-person status hearing set for 7/30/25 at 9:30 a.m. in courtroom 1925. Discovery is closed. The parties are encouraged to resolve the remaining claims via settlement, and if they do so, may file a stipulation to dismiss prior to the next hearing and it will be canceled. Otherwise, the parties should be prepared to discuss the next steps in this case. Because this is a pivotal point in the case, the Court will hold this in-person and is not receptive to video or phone requests. Mailed notice

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for release of bond obligation

MINUTE entry before the Honorable Sunil R. Harjani: In-person status hearing held. For the reasons stated on the record, Plaintiff's motion for release of bond obligation [141] is denied without prejudice. Counsel advised that discovery is finalized, but the parties are still apart on settlement. This case is referred to the designated magistrate judge for settlement discussions. The Court believes the parties will benefit from some ex parte settlement discussions with the magistrate judge, particularly with the clients involved as they are in China and may not fully understand the time and resources it will take to continue to litigate this case. If settlement talks are unsuccessful, cross motions for summary judgment are due 10/17/2025. Response briefs are due 12/1/2025. Replies are due 12/22/2025. The Court will issue a written ruling via CM/ECF. Finally, Mr. DeWitty appeared in person today and apologized for missing the prior hearings before the magistrate judge. Mailed notice

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Keri L. Holleb Hotaling for the purpose of holding proceedings related to: settlement conference. Mailed notice.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter has been re-referred to Judge Holleb Hotaling for settlement. Judge Holleb Hotaling sets an off-the-record pre-settlement conference telephone call for 8/11/2025 at 10:45 a.m. The parties should ensure they call in ONLY at their designated time and not earlier to ensure the pre-settlement call remains private (but not on the record). The counsel that appears for this pre-settlement telephone discussion must be counsel who will represent their respective clients at the conference, or are able to discuss the issues of the case and to schedule the conference on behalf of their clients. The Court expects counsel to discuss issues in the case that may affect the settlement process. Counsel should review Judge Holleb Hotaling's Standing Order on Settlement Conferences prior to the call. The call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

NOTICE of Voluntary Dismissal by Hainan Changyuan Technology Co. Ltd. of ShadowY (No. 15)

MINUTE entry before the Honorable Sunil R. Harjani: Based upon Plaintiff's notice of voluntary dismissal [145], this case is hereby dismissed with prejudice as to the following Defendant: ShadowY. Each party shall bear its own attorney's fees and costs. Mailed notice

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Off-the-record pre-settlement call held on 8/11/2025. A three-hour VIRTUAL (WebEx or Teams) settlement conference with Plaintiff and the remaining Defendants Ridge Washer, Joe Jet, and Mingle Tool, is set for 10/9/2025 at 11:00 a.m. The parties are to arrange for interpreter(s) to be available for the settlement conference for non-English-speaking participants. This date is final and can only be changed by the granting of a motion. By 8/28/2025, Plaintiff's counsel shall send a settlement demand to opposing counsel and to Judge Holleb Hotaling's chambers email, Chambers_HollebHotaling@ilnd.uscourts.gov. By 9/11/2025, Defendants' counsel shall send settlement offer(s) to opposing counsel and to Judge Holleb Hotaling's chambers email. The parties agree Judge Holleb Hotaling may conduct ex parte settlement communications as needed. Additional information about the virtual settlement conference will be forthcoming near the settlement conference date. All participants shall turn on their video for the settlement conference and must join the conference AT LEAST 15 minutes prior to the start to test and resolve any technological issues.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Defendants declined to make an offer in compliance with Judge Holleb Hotaling's Standing Order on Settlement Conferences, as such, the Court does not believe a settlement conference would be fruitful at this time and will strike the settlement conference scheduled for 10/9/2025 at 11:00 am. Judge Harjani's deadlines for cross motions for summary judgement as described in [Docket 142] stand. Discovery is closed and all matters relating to the settlement referral of this case having been resolved, the referral is closed. Judge Holleb Hotaling no longer referred to this case.

MOTION by Defendants RIDGE WASHER, JoeJet, MINGLE Tool for summary judgment

RULE 56 (a)(3) Statement by JoeJet, MINGLE Tool, RIDGE WASHER regarding motion for summary judgment[149]

DECLARATION of Adam E. Urbanczyk regarding motion for summary judgment[149]

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DIGITAL EXHIBIT submitted by JoeJet, MINGLE Tool, RIDGE WASHER regarding [152] For more information, please visit https://www.ilnd.uscourts.gov/ExhibitDrop. If you wish to download a digital exhibit, please send your request to the Certified Copy Desk (CCD) inbox at CCD_ILND@ilnd.uscourts.gov. You will be provided with an invoice and charged according to the Fee Schedule. Once your payment has been processed, you will receive a URL via email to download the exhibit.

DECLARATION of Jie Fang regarding motion for summary judgment 149

MOTION by Defendants JoeJet, MINGLE Tool, RIDGE WASHER for leave to file excess pages

MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for extension of time to file Motion for Summary Judgment

Exhibit Exhibit A-C

RESPONSE by JoeJet, MINGLE Tool, RIDGE WASHERin Opposition to MOTION by Plaintiff Hainan Changyuan Technology Co. Ltd. for extension of time to file Motion for Summary Judgment [156]

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for an extension of time to file a Motion for Summary Judgment [156] is denied because Plaintiff failed to establish good cause for the extension. Mailed notice