2024-cv-09095

COMPLAINT filed by Crye Precision LLC; Filing fee $ 405, receipt number AILNDC-22533070.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Crye Precision LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Crye Precision LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Crye Precision LLC

Notice of Claims Involving Trademarks by Crye Precision LLC

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Kahlia Roe Halpern

ATTORNEY Appearance for Plaintiff Crye Precision LLC by Andrew Daniel Burnham

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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

MOTION by Plaintiff Crye Precision LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Crye Precision LLC in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Jonathan E. Antone regarding memorandum in support of motion 14

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Crye Precision LLC Exhibit 2 Parts 1-2 regarding declaration 16

Exhibit 2-1

(Exhibit 2-2)

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

MEMORANDUM by Crye Precision LLC in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [13] is granted. Plaintiff's motion for leave to file under seal [3] and motion for electronic service of process [18] are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 10/15/2024.

Registry Deposit Information Form by Crye Precision LLC

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

INJUNCTION BOND in the amount of $ 87,000 posted by Crye Precision LLC (Document not scanned)

NOTICE of Voluntary Dismissal by Crye Precision LLC as to Certain Defendants

MOTION by Plaintiff Crye Precision LLC for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Crye Precision LLC in support of motion for preliminary injunction 26

Declaration of Kahlia R. Halpern

(Exhibit 1)

SUMMONS Returned Executed by Crye Precision LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/24/2024, answer due 11/14/2024.

Declaration of Andrew D. Burnham

(Exhibit A)

MOTION by Plaintiff Crye Precision LLC for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by Crye Precision LLC in support of motion for preliminary injunction[29]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by Crye Precision LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/29/2024, answer due 11/19/2024.

Declaration of Andrew D. Burnham

Exhibit A

MINUTE entry before the Honorable Mary M. Rowland: Any objection to Plaintiff's motions for preliminary injunction as to certain defendants 29 26 due 11/6/24. Plaintiff to file a status report on 11/12/24. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

STATUS Report Pursuant to [32] by Crye Precision LLC

Exhibit A

ATTORNEY Appearance for Defendants QURBERRY, Shenzhen Jingye Accessories Co., Ltd. by Haipeng Xiao

MINUTE entry before the Honorable Mary M. Rowland: The court has received no objection to the motions for preliminary injunction. The motions for preliminary injunction [26] [29] are granted. Enter Order. The Clerk is directed to unseal any previously sealed documents in this matter. 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 located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Status report due 12/20/24. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 11/13/2024. Mailed notice.

NEW PARTIES: Foshan CCH Textile Co., Ltd., Foshan Hengsha Jingwei Cloth Co., Ltd., Guangxi Pengda Garment Co., Ltd., Guangzhou Junyi Outdoor Products Co., Ltd., Hebei Fuzhi Import And Export Trading Co., Ltd., Jianyang Huayu Clothing Co., Ltd., Loveslf Company Limited, Nanjing Zennison Outdoor Equipment Co., Ltd., Qiyu (Xiamen) Outdoor Products Co.,ltd., Shaoxing Rigu Textiles Co., Ltd., Shenzhen Jingye Accessories Co., Ltd., Shenzhen Sansheng Textile & Leather Co., Ltd., Shenzhen Yuanjie Technology Co., Ltd., SHIJIAZHUANG QIAN FANG IMPORT AND EXPORT TRADE CO.,LTD, Songyang Huayili Garment Co., Ltd., Suzhou Suly Textile Co., Ltd., Suzhou Texshow Textile Co., Ltd., Taizhou Shentong Tools Manufacturing Co., Ltd., Wuhan Corhunter Garment Co., Ltd., Xiamen Outdoorgo Trading Co., Ltd., Yiwu Aiyi Clothing Co., Ltd, Yiwu Chuangju Belt Factory, Yiwu Goollywood Commercial And Trade Co., Ltd., Zhejiang Dongshi Clothing Co., Ltd., ATAIRSOFT, Clearlovecsf, Qizhi Trading, QURBERRY, ZAPT, genuinerareuniform, genuinerareuniforms_02, khpha54, TopCostumes, Musion Racing Sports, beiweidianzi, Better Like, BOXIANGTAIFUSHI, CGMDTZ, chenghaojiaoyuzixun, Dracceev, dzxyzu, Fanxing, Florida Maniacs Club, foshanshialeixinshangmao, foshanshidiaofudaoshangmao, foshanshixiangluheshangmao, foshanshiyangdundeshangmao, gfddgdfgdfghf, guangzhougengyayishuwenhuayouxiangongsi, guangzhoujinruishangmao, HuanJin, jiang20094e, jiezhishangmaoyou, jingdanshangmao, LYHWHD, MEAGAOME, OLCKL, Old California, OWNMEMORY, OWNNI, OWNSERIES, Papeey, rangedianzi, rweyuibmSTE, shugengshangmao, taininuomaoyi, TJXYMY, TPUPhoneCase, weikewulianjishugongsi, weizhuqianshangmao, WuHanShiYinXiang, xinmingstore, xinxinchuangrongxinxikeji, XTCSDZSW, xuezhi, XW BALD EAGLE, Yuanying, Yuanzhou Technology, YuKaiPing, ZB-HRGBZ, Zestful, Zhengchupao trading co., ltd, zhenmin and ZhongXiangShi added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

ANSWER to Complaint with Jury Demand by QURBERRY

ANSWER to Complaint with Jury Demand by Shenzhen Jingye Accessories Co., Ltd.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendants

MOTION by Plaintiff Crye Precision LLC for entry of default, MOTION by Plaintiff Crye Precision LLC for default judgment as to Certain Defendants

(Exhibit A)

MEMORANDUM by Crye Precision LLC in support of motion for entry of default, motion for default judgment 42

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 43

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed Plaintiff's motion for entry of default and default judgment as to certain defendants 42. Any response is due 1/3/2025. A written status report is due by 1/10/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

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.

Motion by QURBERRY, Shenzhen Jingye Accessories Co., Ltd. to Modify the Asset Restraint

Declaration by Lin Chen for Shenzhen Jingye

Declaration by Xinru Wang for QURBERRY

Exhibit A for Shenzhen Jingye

(Exhibit B for QURBERRY)

MINUTE entry before the Honorable Mary M. Rowland: Motion is set for video hearing via webex on 1/28/25 at 9:30 AM Central time. Parties are encouraged to resolve this matter prior to that date. Mailed notice.

STATUS Report Pursuant to 45 by Crye Precision LLC

(Exhibit A)

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report 50. The Court grants the motion for default. 42 Enter order. Hearing remains set for 1/28/25 at 9:30 AM. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 1/13/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

MINUTE entry before the Honorable Mary M. Rowland: Status hearing held. Parties appeared by phone. Parties report they have reached settlement for both Qurberry and defendant 12. Remaining settlement agreements will be completed by next week. Status report due 2/10/25. Mailed notice.

NOTICE of Voluntary Dismissal by Crye Precision LLC as to certain defendant

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff has dismissed the final two defendants 55 53. The Court strikes the status report due on 2/10/25. 54. This matter is closed. Civil case terminated. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 1/31/2025)

FULL SATISFACTION of Judgment regarding Default Judgment 52 in the amount of $50,000 as to certain defendant

NOTICE of withdrawal of injunction bond 24 by John Summerfield (Received at the Intake Counter on 10/2/2025)