2024-cv-08775

COMPLAINT Redacted Complaint filed by John Doe; Jury Demand. Filing fee $ 405, receipt number AILNDC-22511046.

(Exhibit Exhibit 3)

SEALED DOCUMENT by Plaintiff John Doe Exhibit 1 to Redacted Complaint

SEALED DOCUMENT by Plaintiff John Doe Exhibit 2 to Redacted Complaint

SEALED DOCUMENT by Plaintiff John Doe Schedule A to Redacted Complaint

SEALED DOCUMENT by Plaintiff John Doe Unredacted Complaint

Exhibit Exhibit 1 to Unredacted Complaint

Exhibit Exhibit 2 to Unredacted Complaint

Exhibit Exhibit 3 to Unredacted Complaint

(Exhibit Schedule A to Unredacted Complaint)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by John Doe

SEALED DOCUMENT by Plaintiff John Doe Notice of Trademark Claim

CASE ASSIGNED to the Honorable Jorge L. Alonso. 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.)

ORDER: Local Rule 3.1 requires at the time of filing a case, plaintiff's counsel, or if the case is filed pro se, the plaintiff shall file with the original papers a completed designation sheet (civil cover sheet). No civil cover sheet was submitted at the time of filing this matter. John Doe is directed to file the Civil Cover Sheet within 14 days of this notification. Signed by the Executive Committee.

MOTION by Plaintiff John Doe for temporary restraining order

MEMORANDUM by John Doe in support of motion for temporary restraining order 9 Redacted Memorandum in Support of Plaintiff's Motion for Entry of Temporary Restraining Order

SEALED DOCUMENT by Plaintiff John Doe Unredacted Memorandum in Support of Ex Parte Temporary Restraining Order

SEALED DOCUMENT by Plaintiff John Doe Declaration of Plaintiff in Support of Motion for Temporary Restraining Order

Exhibit Exhibit 1

Exhibit Exhibit 2

Exhibit Exhibit 3

Exhibit Exhibit 4A

Exhibit Exhibit 4B

Exhibit Exhibit 4C

Exhibit Exhibit 4D

Exhibit Exhibit 4E

Exhibit Exhibit 4F

Exhibit Exhibit 4G

Exhibit Exhibit 4H

Exhibit Exhibit 4I

Exhibit Exhibit 4J

Exhibit Exhibit 4K

Exhibit Exhibit 4L

Exhibit Exhibit 4M

Exhibit Exhibit 4N

Exhibit Exhibit 4O

Exhibit Exhibit 4P

Exhibit Exhibit 4Q

Exhibit Exhibit 4R

Exhibit Exhibit 4S

Exhibit Exhibit 4T

Exhibit Exhibit 4U

Exhibit Exhibit 4V

Exhibit Exhibit 4W

Exhibit Exhibit 4X

Exhibit Exhibit 4Y

Exhibit Exhibit 4Z

Exhibit Exhibit 4AA

Exhibit Exhibit 4BB

Exhibit Exhibit 4CC

Exhibit Exhibit 4DD

(Exhibit Exhibit 4EE)

MOTION by Plaintiff John Doe for service by publication

MEMORANDUM by John Doe in support of motion for service by publication 13

MOTION by Plaintiff John Doe to seal document sealed document 7, sealed document 4, sealed document, 5, sealed document 2, sealed document, 12, sealed document 11, sealed document 3

ATTORNEY Appearance for Plaintiff John Doe by Brandon Matthew Beymer

ATTORNEY Appearance for Plaintiff John Doe by Daliah Saper

CIVIL Cover Sheet

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion to seal document 15, motion for temporary restraining order 9, motion for service by publication 13 before Honorable Jorge L. Alonso on 9/26/2024 at 09:30 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's ex parte motions 9 13 15 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $111,000$1,000 per defendantis sufficient to secure the injunctive relief. Motion hearing set for 9/26/24 is stricken. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Minute entry dated 9/25/24 22 is corrected as follows: Plaintiff's ex parte motions 3 15 20 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $261,000 -- $1,000 per defendant -- is sufficient to secure the injunctive relief. Motion hearing set for 9/26/24 is stricken.Notice mailed by Judge's staff

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 9/25/2024. Notice mailed by Judge's staff

Surety BOND in the amount of $ 261,000 posted by John Doe. (Document not Imaged)

MOTION by Plaintiff John Doe for extension of time to Extend the Temporary Restraining Order

NOTICE of Motion by Brandon Matthew Beymer for presentment of extension of time 26 before Honorable Jorge L. Alonso on 10/9/2024 at 09:30 AM.

MINUTE entry before the Honorable Jorge L. Alonso: Plaintiff's Motion to extend ex parte temporary restraining order 26 is granted. The temporary restraining order is extended for 14 days to 10/23/24. Motion hearing date of 10/9/24 is stricken. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by John Doe for Defendant 122 "VZZNN"

NOTICE of Voluntary Dismissal by John Doe for Defendants 57 KoreahighI 196 Afunyo and 255 Dxzksp

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

NOTICE of Voluntary Dismissal by John Doe for Defendant 116 "NIU B STORE"

MOTION by Plaintiff John Doe for preliminary injunction as to the Defendants on the redacted Schedule A

(Exhibit Schedule A)

MEMORANDUM by John Doe in support of motion for preliminary injunction 32

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for preliminary injunction 32 before Honorable Jorge L. Alonso on 10/23/2024 at 09:30 PM.

SUMMONS Returned Executed by John Doe as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/18/2024, answer due 11/8/2024.

(Affidavit Affidavit of Service)

NOTICE of Voluntary Dismissal by John Doe for Defendants 74 "CIREA" 113 "QianJiangShiGuoNianWenShangMaoYouXianGongSi" and 151 "QianLoongCH"

NOTICE of Voluntary Dismissal by John Doe for Defendants 88, 101, 164, 171, 176, 187, 190, 192, 195, 199, 209, 212, 215, 216, 217, 218, 219, 220, 221, 225, 226, 227, 229, 230, 235, 236, 237, 238, 240, 248, and 256

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing set for 10/23/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Notice mailed by Judge's staff

MOTION by Plaintiff John Doe for preliminary injunction as to the Defendants on Schedule A

(Exhibit Schedule A)

MEMORANDUM by John Doe in support of motion for preliminary injunction 39

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for preliminary injunction 39 before Honorable Jorge L. Alonso on 10/29/2024 at 09:30 AM.

SUMMONS Returned Executed by John Doe as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/23/2024, answer due 11/13/2024.

(Affidavit Affidavit of Service)

ATTORNEY Appearance for Defendant Good Friiends by Hua Chen

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic motion hearing held. Plaintiff's Motion for entry of preliminary injunction 32 is granted. Enter Preliminary Injunction Order. Plaintiff 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 at www.ilnd.uscourts.gov. Telephonic status hearing set for 10/29/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 888-808-6929 and the access code is 4911854. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. 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. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/29/2024. Notice mailed by Judge's staff Modified on 10/29/2024.

NOTICE of Voluntary Dismissal by John Doe for Defendants 77 "Dakk" 214 "MF Supply" and 252 "SHIYI Co.Ltd"

NOTICE of Voluntary Dismissal by John Doe for Defendant 87 "Miyamarch"

NOTICE of Voluntary Dismissal by John Doe for Defendant 241 "shenzhenshiruigeerdianzishangwuyouxiangongsi"

ATTORNEY Appearance for Defendant FENGTI Co., Ltd. by He Cheng

MOTION by Defendant FENGTI Co., Ltd. to dismiss for lack of jurisdiction

(Exhibit Exhibit 1 - Declaration of Weifeng Li)

NOTICE of Voluntary Dismissal by John Doe for Defendants 95 "MengWeiDianZi" and 121 "BrightSummit"

NEW PARTIES: Guangzhou Hair I Need Trading Co., Ltd., Dongguan Easybae Technology Co., Ltd., Dongguan Laboer Technology CO., LTD, Guangzhou Furgerin Technology Co., Ltd., Luoding Pingtang Yuyuan Comb Factory, Guangzhou Lucky Girl Fashion Accessories Co., Ltd., Shangrao Lvjie Daily Necessities Co., Ltd., Nanjing Miou International Trade Co., Ltd., Guangzhou Kalinda Trading Co., Ltd., Ningbo Royal Union Co., Ltd., Zhuji Maocheng Import And Export Co., Ltd., Ningbo Sinle Import Export Co., Ltd., Shenzhen Yishangzhuo Industrial Technology Co., Ltd., Bocheng Network Technology (Yiwu) Co., Ltd., Yiwu Yiwo Import And Export Co., Ltd., Ningbo Kinpack Commodity Co., Ltd., Alice Dream, Shop5633137 Store, SunFay Warm Store, Makeup Wonderland Store, QUEEON Makeup Store, Healthy feet Tools Store, WanMei Beauty Store, Tianyi makeup Store, Huawei Choice2 Store, Fashion Beauty Makeup Store, Confident Beautiful Rich Girls Store, BEST Dropshipping Store, MeiLaMei Beauty Store, Kalman Cosmetics Strong Supplier Store, Lucky Coming Store, Luckin Come Store, YiGetRich0 Store, Shop1103276603 Store, Fashion Beauty Makeup Store, WODEC Home And Tools Supermarket Store, Omsblkin Beauty And Skin Care Store, Shop1103438302 Store, Shop1103539126 Store, MAGIC PANDA Store, Fuyuan Beauty Store, Shop1103596835 Store, Shop1103702087 Store, Shop1103698168 Store, ZGD Store, LA ROCHE-PSAY Dropshipping Store and Shop1103530971 Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: Shop1103692353 Store, BeautyChoioe, God Nos, Fangshare, Lightning Deals of Today (7-15 Days Arrival), GUAAJA (7-14 days Deliver), (Zhangchao Skirt Jiong Trade), JIESENG, liukehui, KoreahighI, chophilly&co, Zhuwshop, DoggieCC, HanYanHuanShangMao, CYQSHOPONE, basior, weihanjunshop, 3yyy, EniS, ganzhourunshuodianzishangwu, LIUYANXUJIEMENGXIANGKONGJIAN, HuBeiShengFaYunTongShangMaoYouXianGongSi, Ellobin, A Lucky day, PP-Home & Kitchen-Shop, Lianshengshangmao, CIREA, lingcvnq1, Zakrea Store, Dakk, precipitate, HongDuo, MIC store, BAIJIESP, The Felipe Group, LinQunShengUS, WorldwideSweetHome, Magic AAA, Hot Deals (7-12 Days Arrival), Miyamarch, ggogo, LANNAO Store, zhengzhoujuntiaoxinxijishuyouxiangongsi, (Soil Soil Soil), chuanyankuajing, Mymlang, ningchengxianhuihengdedianzishangwushanghang, MengWeiDianZi, WANSHENGJINFU, Wbeng, (Kunming Junlu E-commerce Co., Ltd.), Inviclex, Aries'Wonderful Life Hall, GreenJoy., NadhehNad Shop, Luminary You, Bright Wo., Kizaia, Haibrush, Yam ldf, Qh Store, UCGSMHTO, keerqinquyunzhongriyongpindian, Mllkcao1, SHEN SI JUN, QianJiangShiGuoNianWenShangMaoYouXianGongSi, DDEET, zhangyifan01, NIU B STORE, KJHUHDS, chuanghuishangmaoyouxiangongsi, Good things shared, kylinss, BrightSummit and VZZNN added to case caption. (Text entry; no document attached.)

NEW PARTIES: Blissi, CurryAndKartoffeln, Ygulnn (3-14 Days Delivery), Zhuodi Jewelry Lifestyle Store, DEATU 20% - 30% Off, Luohgy_Store, LIUZHUANGKUAICHUSUSHANGMAO, ELLO SPECIALS, The JIEREYAN Store, Liws, Ocacion shop, guan06 Store and asagunas_4 added to case caption. (Text entry; no document attached.)

NEW PARTIES: Australian.Pharma, benflores-2, cenqinghu-shop, chabe_112327, fatinsyahi_0, ftmh9980, gaiobgnag55d, goodforu-store, green_life23, harith553, Hannahs Boutique shop, hhmh9987, hlmh3688, hotfashioncong2022, jaggyr_556, QianLoongCH, JJT, Mia's Boutique shop, YGZSGZ, mjmh6677, mm_khan, Zoey Boutique shop, mosaic26, muhammad0519, mzmh6521, nopparatjittapupitak41, nufonpo63, pattaramo-98, qikaguu86, qingz-0, ratchanokcheewaseree50, rjmh3258, soteracity, ssgd1968, Beautifuljewelry2, tan_shu-37, TarasStore, Malia's Boutique shop, westli-52, yoojiotu4, younipoo26, Buy of enjoyment, zimopuu52, bresebeauty.com, brushher.nl, keytielands.myshopify.com, nooknestonlinestore.com, Factory DIAN PU, BOOSE, PURESTAR, PSD A, Hanzidakd Clothing, Timerunfa, CAKVIICA INC, Gomind LLC, guangzhoushiyiqikeji, EnchantGlow, Brenberke INC, Betiyuaoe, Afunyo, ComfortMart, YUEBAO Co.Ltd, PANRICH and MilaMlAmor added to case caption. (Text entry; no document attached.)

NEW PARTIES: ShenZhenShiNuoWeiTongDianZiShangWuYouXianGongSi, MilaMiAmior, Juxin Wan Store, Deyishang, Maple leaf, zhongjianyong, G2G, huokairuishangmaoyouxian, Weyolog, JABUUO, UGG, An An Sheng Co., Ltd., Yizheng International, MF Supply, CZYSHP, WozlgeNB, BBZUI, Rowett, Newband, Uoyii Fashion, Anriop, yisonow, Viku Daty, zhouyuesishangmaoyouxiango, YJJFHDSH, IZFHT, SUJITO Co.Ltd, HAIZU Co.Ltd, YIQING BEAUTY MALL, Good luck, kdingakejkhknfgejdu, sea moss, Waldeals, jinzPJ, guangzhouhanyongqikejiyouxiangongsi, Vueong, Miauyi, Mixicoe, BAOshuiza, shenzhenshiruigeerdianzishangwuyouxiangongsi, hongcongsuye, jiajianzhaoming, hrtcs, 3melife, naiste, qiashens, WIOLXU, GuangZhouTaoShunShangMaoYouXianGongSi, WBIOPY SHOP, jingdanshangmao, SHIYI Co.Ltd, DIANNAO Co.Ltd, tanglingmaoyi, Dxzksp, Suimingjian Co., Ltd., youme1, JYB, cwline, ninetysenen and xiaoqunhui added to case caption. (Text entry; no document attached.)

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 11/21/24 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of preliminary injunction 39 is granted. Enter Preliminary injunction order. Plaintiff's response to Defendant No. 234, FENGTI Co. Ltd.'s Motion to dismiss under rule 12(b)(2) and incorporated memorandum of law 48 shall be filed by 11/25/24; Defendant's reply shall be filed by 12/9/24. Notice mailed by Judge's staff

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 10/29/2024. Notice mailed by Judge's staff

NOTICE of Voluntary Dismissal by John Doe for Defendants 7 "Shangrao Lvjie Daily Necessities Co., Ltd." and 142 "gaiobgnag55d"

NOTICE of Voluntary Dismissal by John Doe for Defendant 253 "DIANNAO Co.Ltd"

STIPULATION of Dismissal for Defendant 189 shenzhenshiliyuandianzishangwuyouxiangongsi d/b/a "Good Friiends"

STIPULATION of Dismissal for Defendant 234 "FENGTICo.Ltd"

NOTICE of Voluntary Dismissal by John Doe for Defendant 114 "DDEET"

NOTICE of Voluntary Dismissal by John Doe for Defendants 65, 194, 197, 233, 239, and 257

MOTION by Plaintiff John Doe for entry of default, MOTION by Plaintiff John Doe for default judgment as to the Defendants on the redacted Schedule A

(Exhibit Schedule A)

MEMORANDUM by John Doe in support of motion for entry of default, motion for default judgment 60

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for entry of default, motion for default judgment 60 before Honorable Jorge L. Alonso on 11/21/2024 at 09:30 AM.

NOTICE of Voluntary Dismissal by John Doe for Defendant 5 "Luoding Pingtang Yuyuan Comb Factory"

NOTICE of Voluntary Dismissal by John Doe for Defendants 105 "Kizaia" and 158 "mosaic--26"

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing set for 11/21/24 at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. 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. Notice mailed by Judge's staff

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment 60 is granted. Enter Final Default Judgment Order. Defendant FENGTI Co., Ltd's Motion to dismiss under rule 12(b)(2) and incorporated memorandum of law 48 is denied as moot. Civil case terminated. Notice mailed by Judge's staff

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 11/21/2024. Notice mailed by Judge's staff

MAILED trademark report with order dated 11/21/2024 to Patent Trademark Office, Alexandria VA

MAILED original two hundred sixty one-thousand-dollar ($261,000) surety bond posted by Luxury Brands LLC to Saper Law Offices, Llc 505 N. Lasalle Street Suite 350 Suite 350 Chicago, IL 60654 via certified mail # 9589 0710 5270 0579 7785 29. (Text entry; no document attached.)

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7785 29.

FULL SATISFACTION of Judgment regarding order, terminated case 67 in the amount of $400,000 for Defendant 186 "PSD A"

FULL SATISFACTION of Judgment regarding order, terminated case 67 in the amount of $400,000 for Defendant 98 "Kunming Junlu E-commerce Co., Ltd.

FULL SATISFACTION of Judgment regarding order, terminated case 67 in the amount of $400,000 for Defendant 201 "ShenZhenShiNuoWeiTongDianZiShangWuYouXianGongSi"

FULL SATISFACTION of Judgment regarding order, terminated case 67 in the amount of $400,000 for Defendants 231, 243, 246, and 249

FULL SATISFACTION of Judgment regarding order, terminated case 67 in the amount of $400,000 for Defendant 102 "NadhehNad Shop" and Defendant 127 "DEATU 20% - 30% Off"