2024-cv-08318

COMPLAINT filed by Bigfoot 4x4, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-22466920.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Bigfoot 4x4, Inc. by John Wilson

MOTION by Plaintiff Bigfoot 4x4, Inc. to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bigfoot 4x4, Inc.

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. Case assignment: Random assignment. (Civil Category 2). (qrtr,)

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. (qrtr,)

MOTION by Plaintiff Bigfoot 4x4, Inc. for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Bigfoot 4x4, Inc. 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 Bigfoot 4x4, Inc. in support of motion for temporary restraining order, 11

Declaration Trent Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 1 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 2 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 3 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 4 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 5 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 6 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 7 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 8 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 9 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 10 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 11 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 12 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 13 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 14 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 15 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 16 of Trent Declaration

SEALED DOCUMENT by Plaintiff Bigfoot 4x4, Inc. Exhibit 2 Part 17 of Trent Declaration

Notice of Claims Involving Trademarks by Bigfoot 4x4, Inc.

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's 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/or electronic publication 11, motion for leave to file under seal 7, and motion to exceed page limitation 10. Provided that Plaintiff provides the security described in paragraph 13 of the temporary restraining order, the temporary restraining order shall become effective on 09/17/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Bigfoot 4x4, Inc. (Document not scanned).

MOTION by Plaintiff Bigfoot 4x4, Inc. for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order 36. The Temporary Restraining Order 34 shall now expire on 10/15/2024 at 6:00 p.m. Mailed notice.

MOTION by Plaintiff Bigfoot 4x4, Inc. for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

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

MEMORANDUM by Bigfoot 4x4, Inc. in support of motion for preliminary injunction 40

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 40

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

SUMMONS Returned Executed by Bigfoot 4x4, Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 10/10/2024, answer due 10/31/2024.

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction 40 is granted. Enter Preliminary Injunction Order as amended. The following documents are to be unsealed: (1) Schedule A to the Complaint 8 ; (2) Exhibit 2 to the Declaration of Ann Trent [13-29]; and (3) the TRO 34. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Franklin U. Valderrama on 10/14/2024. Mailed notice.

NEW PARTIES: ZTZPIE, ZOUYUE, xiaolong888, xiangyangshifuniushangmao, WQEIOTUPORT, JSHIGUANG, guanjiangkuajing, guangzhouzhannimaoyi, guangzhouaijianong, Gongbei Tech Co.,Ltd, foshanshiyuhengyankeji, foshanguangji, Zhejiang Fantong Trading Co., Ltd., Yiwu Xuanlin Toys Co., Ltd., Yiwu Xifu Toy Firm, Shenzhen Fast Dog International Logistics Co., Ltd., Shenzhen Canda Technology Co., Ltd., Shenzhen Atibei Technology Co., Ltd., Shengzhou Boan Trading Co., Ltd., Shantou Zoya Leemook Plastic Product Co., Ltd., Shantou Xinfei Toys Co., Ltd., Shantou Wingo Toys Factory, Shantou Weiyi Trading Co., Ltd., Shantou Toyhome Toys Co., Ltd., Shantou Nan Huang Toys Co., Ltd., Shantou Liansheng Toys Co., Ltd., Shantou Denko Toys Co., Limited, Shantou Cy Hobby Toy Factory, Shantou City Longhu District Taolehui Toy Shop, Shantou City Bhx Toys Co., Ltd., Shantou Chenghai Beishida Toys Co., Ltd., QINGDAO AUFINE TYRE CO., LTD., Market Union Co., Ltd., Leqihao Technology (Shanghai) Co., Ltd, Guangxi Karisin E-Commerce Co., Ltd., Chifu Network Technology (xuzhou) Co., Ltd., YSDTHL Hydroponics Flagship, SUSSLI US Toy Factory, SummitLink, qoock-us, Qiyuanxu, Qiclear Marine Direct, Obelia-s, NTF-Metal Tech, Naxue Nasode, MNGFJD-US, JiNanJuanQiFuShangMaoYouXianGongSi, JENNIY, HIFUN Store, DENGZHOUSHIYUMIAOBAIHUODIAN, Buildmat Store, yiqimaoyi, tianjinmeierjia, QRIOUROPET, KEKAIFAN, JIAXUXI, IOQWEUOPT, huangzhimaoyi, chengduxuanhanmishangmaoyouxiangongsi and Guangzhou Cool Fun Baby Products Co., Ltd. added to case caption.

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 238

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

ATTORNEY Appearance for Defendant Qiyuanxu by Mark K. Suri

ANSWER to Complaint with Jury Demand by Qiyuanxu

NOTICE of Voluntary Dismissal by Bigfoot 4x4, Inc. Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 136

CERTIFICATE of Service by John Wilson on behalf of Bigfoot 4x4, Inc.

MOTION by Plaintiff Bigfoot 4x4, Inc. 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 Bigfoot 4x4, Inc. in support of motion for default judgment 54

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 54

(Exhibit Hierl Exhibit 1)

MINUTE entry before the Honorable Franklin U. Valderrama: Plaintiff's Motion for Entry of Default and Default Judgment against the Defendants Identified in Amended Schedule A 54 is granted. Enter Final Judgment Order as amended. The ten-thousand-dollar ($10,000.00) surety bond posted by Hughes Socol Piers Resnick & Dym, Ltd., including any interest minus the registry fee, is hereby released to Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court 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. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 11/15/2024. Mailed notice. (jcm) (Main Document 58 replaced on 11/15/2024).

SATISFACTION of Judgment

SATISFACTION of Judgment

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Bigfoot 4x4, Inc. 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 # 7001 2510 0005 7681 7983. (jn,)

MAILED trademark report with certified copy of minute order dated 11/15/2024 to Patent Trademark Office, Alexandria VA. (jn,)

STIPULATION Stipulation of Voluntary Dismissal with Prejudice

RETURN of U.S. Post Office Receipt, article no. 7001 2510 0005 7681 7983. (Received by mail in the Clerk's Office on 12/17/24)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the parties' stipulation of voluntary dismissal 62, which dismisses Plaintiff's complaint against the last remaining defendant in this case. Pursuant to the parties' stipulation 62 and pursuant to Federal Rule of Civil Procedure 41(a), this case is dismissed with prejudice against Defendant No. 82 Qiyuanxu, with each party to bear its own fees and costs. Civil case terminated. Mailed notice.

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment

SATISFACTION of Judgment