2024-cv-10628

COMPLAINT filed by Those Characters from Cleveland, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-22616047.

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff Those Characters from Cleveland, LLC by John Wilson

MOTION by Plaintiff Those Characters from Cleveland, LLC to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Those Characters from Cleveland, LLC

CASE ASSIGNED to the Honorable Sharon Johnson Coleman. Designated as Magistrate Judge the Honorable Maria Valdez. Case assignment: Random assignment. (Civil Category 2).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MINUTE entry before the Honorable Sharon Johnson Coleman: This case has been assigned to the calendar of Judge Sharon Johnson Coleman. Plaintiff is put on notice that it may be required to file a memorandum discussing the propriety of joinder under Federal Rule of Civil Procedure 20(a)(2) if it appears that defendants are too numerous or unconnected. In addition, should default judgment enter against defendant(s), Plaintiff should be prepared to prove up damages by affidavit or hearing. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

AMENDED complaint by Those Characters from Cleveland, LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Amended Schedule A Hereto

Exhibit 1

Exhibit 2 Part 1

(Exhibit 2 Part 2)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Amended Schedule A

MOTION by Plaintiff Those Characters from Cleveland, LLC for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 Those Characters from Cleveland, LLC in support of motion for temporary restraining order, 15

Declaration Gorman Declaration

Exhibit 1

Exhibit 2 Part 1

Exhibit 2 Part 2

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

Exhibit Hierl Exhibit 3

(Exhibit Hierl Exhibit 4)

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 1 of Gorman Declaration

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 2 of Gorman Declaration

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 3 of Gorman Declaration

SEALED DOCUMENT by Plaintiff Those Characters from Cleveland, LLC Exhibit 3 Part 4 of Gorman Declaration

Notice of Claims Involving Trademarks by Those Characters from Cleveland, LLC

NOTICE of Motion by Michael A. Hierl for presentment of motion to seal document 7, motion for leave to file excess pages 14, motion for temporary restraining order, 15 before Honorable Sharon Johnson Coleman on 10/29/2024 at 10:00 AM.

MEMORANDUM by Those Characters from Cleveland, LLC Plaintiff's Memorandum in Support of Joinder

(Exhibit 1)

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 10/29/2024. Plaintiff's motion for leave to file under seal 7, motion to exceed page limitation 14, and 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 15 are granted. Enter Order. An in-person status hearing is set for 11/12/2024 at 10:00 AM. Mailed notice.

SEALED ORDER. Signed by the Honorable Sharon Johnson Coleman on 10/29/2024. Mailed notice.

SURETY BOND in the amount of $ 10,000 posted by Those Characters from Cleveland, LLC. (Document not imaged)

MOTION by Plaintiff Those Characters from Cleveland, LLC for extension of time Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order

NOTICE of Motion by Michael A. Hierl for presentment of extension of time 27 before Honorable Sharon Johnson Coleman on 11/12/2024 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 11/12/2024. Plaintiff's ex parte motion to extend the temporary restraining order 27 is granted. The Temporary Restraining Order is extended to 11/26/2024. An in-person status hearing is set for 11/22/2024 at 10:15 AM. Mailed notice.

MOTION by Plaintiff Those Characters from Cleveland, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for preliminary injunction 30

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 30

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 30 before Honorable Sharon Johnson Coleman on 11/22/2024 at 10:15 AM.

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

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Amended Schedule A Hereto on 11/19/2024, answer due 12/10/2024.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 11/22/2024. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction against certain defendants 30 is granted. Enter Order. Oral motion by plaintiff to extend the temporary restraining order on the remaining 15 defendants not included in the preliminary injunction is granted. The Temporary Restraining Order as to the 15 defendants not included in the preliminary injunction is extended to 12/10/2024. An in-person status hearing is set for 12/6/2024 at 10:45 AM. Law Firm of Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 11/22/2024. Mailed notice.

NEW PARTIES: Lux Outlet Store, Yiwu Kaixi Imp. & Exp. Co., Ltd., Xiamen Ubagift Trading Co., Ltd., Shaoxing Bestshow Textile Co., Ltd., NANJING TRUEJOIN INTERNATIONAL TRADING CO. LTD, MAYSUN HK LIMITED, kahire, Guangzhou Youpin Textile Co., Ltd., Guangzhou Feizhenzouxian Clothing Co., Ltd., Guangzhou Caluz Trading Co., Ltd., Chengdu Paideng Clothing Limited Liability Company, Sweetdream Store, Su Jiu High Quality Store, Sombrero Store, Shop1103887718 Store, Shop1103842654 Store, Shop1103587552 Store, Shop1103562129 Store, Shop1103478535 Store, Shop1103333728 Store, Shop1102883199 Store, Shop1102772717 Store, Shop1102770421 Store, RunQiu01 Store, Peace Love Clothing Store, Mu Tong 1 Store, MINISO BASEBALL Store, Kucci Store, Ethereal 428 Store, CS Hats Store, C-2 RISE Store, ali hat Store, YourDesignOrMine2020, Cgrahamstudio, Shop1104028427 Store, Shop1103895031 Store and Digitaling 01 Store added to case caption.

MOTION by Plaintiff Those Characters from Cleveland, LLC for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

MEMORANDUM by Those Characters from Cleveland, LLC in support of motion for preliminary injunction 37

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 37

NOTICE of Motion by Michael A. Hierl for presentment of motion for preliminary injunction 37 before Honorable Sharon Johnson Coleman on 12/6/2024 at 10:45 AM.

SUMMONS Returned Executed by Those Characters from Cleveland, LLC as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Amended Schedule A Hereto on 12/2/2024, answer due 12/23/2024.

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1), this case is dismissed without prejudice as to defendants teepeoples, Joe Joe Monkey, and Young Rebels Clothing UK only. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 12/6/2024. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of a preliminary injunction against certain defendants 37 is granted. Enter Order. The Court directs the Clerk of Court to unseal plaintiff's Amended Schedule A to the Amended Complaint 13, Exhibit 3 to the Declaration of Sean Gorman [17, 18, 19, 20] and the Temporary Restraining Order 25. An in-person status hearing is set for 2/7/2025 at 10:15 AM. Law Firm of Hughes Socol Piers Resnick & Dym, Ltd. is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Sharon Johnson Coleman on 12/6/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NEW PARTIES: Zerofux Clothing Co, The New Shirt Shop, Strong N Free, Rainbow Fabrics, naokahdesigns, Lucky Monkey Apparel, Blue Drop Transfers, BC Australia, mamoic, Halloween Merch, Customization Trend and Arrow Trend Leggings added to case caption.

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1), this case is dismissed with prejudice as to defendants Lux Outlet Store, Blue Drop Transfers, and Strong N Free only. Mailed notice.

MOTION by Defendant Robert Ian Miller to dismiss me from case.

NOTICE by Robert Ian Miller of filing of motion to dismiss 48.

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 Those Characters from Cleveland, LLC Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 269

CERTIFICATE of Service by John Wilson on behalf of Those Characters from Cleveland, LLC

MOTION by Plaintiff Those Characters from Cleveland, LLC 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 Those Characters from Cleveland, LLC in support of motion for default judgment, 53

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 53

(Exhibit Hierl Exhibit 1)

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 53 before Honorable Sharon Johnson Coleman on 1/21/2025 at 10:00 AM.

MINUTE entry before the Honorable Sharon Johnson Coleman: Pursuant to Federal Rule of Civil Procedure 41(a)(1), this case is dismissed without prejudice as to defendant The New Shirt Shop only. Defendant's motion to dismiss 48 is stricken as moot. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Presentment of Plaintiff's motion for entry of default and default judgment 53 set for 1/21/2025 at 10:00 AM is now proceeding by telephone. The call-in number is 1-650-479-3207, when prompted enter access code 2314 122 0068 #. Members of the public and media will be able to call in to listen to this hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

MINUTE entry before the Honorable Sharon Johnson Coleman: Motion hearing held on 1/21/2025. Defendants did not appear nor contact the Court. Plaintiff's motion for entry of default and default judgment against the defendants identified in Amended Schedule A [53] is granted. Default judgment is entered in favor of the plaintiff and against the remaining defendants identified in the Amended Schedule A. Enter Order. An in-person prove up hearing is set for 2/11/2025 at 9:00 AM. Status hearing set for 2/7/2025 is stricken. The ten thousand dollar ($10,000) surety bond posted by Plaintiff is hereby released to counsel of record for Plaintiff via first class mail, Michael A. Hierl of Hughes Socol Piers Resnick & Dym, Ltd. at Three First National Plaza, 70 W. Madison Street, Suite 4000, Chicago, IL 60602. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Sharon Johnson Coleman on 1/22/2025. Mailed notice.

SATISFACTION of Judgment

MINUTE entry before the Honorable Sharon Johnson Coleman: In light of the filing of the satisfaction of judgment 61, case is dismissed. Prove up hearing set for 2/11/2025 is stricken. Civil case terminated. Mailed notice.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Those Characters from Cleveland, LLC to their attorney 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 7891. (jn,)

MAILED trademark report with certified copy dated 1/30/2025 to Patent Trademark Office, Alexandria VA. (jn,)

RETURN of of U.S. Post Office Receipt, article no. 7001 2510 0005 7681 7891. (Received by mail in the Clerk's Office on 3/3/2025)

SATISFACTION of Judgment