2024-cv-12015

COMPLAINT filed by United States Olympic and Paralympic Committee; Filing fee $ 405, receipt number AILNDC-22759070.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff United States Olympic and Paralympic Committee Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Keith A. Vogt

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Yanling Jiang

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Yi Bu

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Adam Grodman

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Monica Rita Martin

ATTORNEY Appearance for Plaintiff United States Olympic and Paralympic Committee by Christopher Romero

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by United States Olympic and Paralympic Committee

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

(Trademarks)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff should review the Court's standing order on "Schedule A" Cases, available at https://www.ilnd.uscourts.gov/judge-info.aspx?IuUaWzNcEoPr4PHl9tvcGaMUezk8AnJ1 under the "Case Procedures" tab. Please note that the table's requirements were revised on October 10, 2024. As explained there, Plaintiff must complete and file the template linked on that page before the Court will consider granting any motion for preliminary injunctive relief. The submission must also provide a listing of all prior Schedule A cases filed in any court in the United States in which Plaintiff was a plaintiff, and a listing of any of the defendants included in the Schedule A in this case that Plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Finally, by filing the template, Plaintiff certifies that Plaintiff has not used any of the screenshot evidence supplied in support of a motion for a TRO in this case in any prior proceeding. If the template is not completed by December 6, 2024, the Court may dismiss this matter for failure to prosecute. Mailed notice.

SEALED DOCUMENT by Plaintiff United States Olympic and Paralympic Committee Schedule A Template Schedule of Defendants to the Complaint [1] and Schedule A [2]

MOTION by Plaintiff United States Olympic and Paralympic Committee for leave to file under seal

MOTION by Plaintiff United States Olympic and Paralympic Committee for leave to file excess pages

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

MEMORANDUM in Support of [17] Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's Declaration

Declaration of Jay Harvey Paragoso

Exhibit 1, of Jay Harvey Paragoso's Declaration

SEALED EXHIBIT by Plaintiff United States Olympic and Paralympic Committee Sealed Exhibit 2, Declaration of Jay Harvey Paragoso regarding memorandum in support of motion, [18]

SURETY BOND in the amount of $ 10,000.00 posted by United States Olympic and Paralympic Committee. (Document not scanned.)

MOTION by Plaintiff United States Olympic and Paralympic Committee for preliminary injunction

MEMORANDUM by United States Olympic and Paralympic Committee in support of motion for preliminary injunction[23]

Declaration of Keith A. Vogt

Exhibit 1, of Keith A. Vogt's Declaration

SUMMONS Returned Executed by United States Olympic and Paralympic Committee as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/12/2024, answer due 1/2/2025.

Declaration of Service

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion [23] 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 December 18, 2024." If no objections are filed by that date, the Court will consider the motion unopposed. 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. For the reasons stated in the Court's orders entering the TRO, the TRO is extended until the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under FRCP 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice.

CERTIFICATE of Service by Plaintiff United States Olympic and Paralympic Committee regarding order on motion for preliminary injunction, text entry, [26]

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction [23] 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 [27] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. 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. Mailed notice.

PRELIMINARY INJUNCTION Order. Signed by the Honorable Lindsay C. Jenkins on 12/19/2024. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NEW PARTIES: Abrahamli, Accovy, Adbnpza, AFTRYG, aiqixindianziyouxiangongsi, AIXIANG Co.Ltd, Almacs, AN LOC TUAN LTD, Anideon, Balajijewels, BFYSFBAIG, Big Wholesaler, blocloalo, Bngzhgl, Boyong, CFJKF, CH-HUIYU, changshashihuicun, CHANGTAO Co.Ltd, Chenqiufeng, CHENZXX, chuangmiaomaoyi, ChuXiongShiJiaYangXian, Coalada, CZIMOO, DanZhouShiHongJinLinGongSi, DongQiuLe, DuiMaXiMaoYi, Elaxen Limited, encouthre, Enjoy trade, EQRBITXL, Everything is 9.99, EWIOQURIOPRT, Fashionlly, Fismartprint, foshanshishaalanshangmao, foshanshiweipiqiaoshangmao, FUCHENG Co.Ltd, GARENAS, GEXUE Co.Ltd, GIWX, gjijishukaifa, GOGMARTI, Good One Day Co. ltd, GoodlW, GTHHNBMM, GuangTongMingShangMao, guangzhouruixinyikejiyouxiangongsi, GUOJIJUYE Co.Ltd, Haute Haven, HDSWvsa, hecxina, hefeininnaoshangmao, hefeinoumishangmao, hehongfushi, Heydday, hfugdbu, Hi-Kater Co. ltd, Hjuang, HongLi Custom factory, hssFGG, huangyiyun, HUMORAND, Hutong Vehicle, indepenlibr, Interesting DIY, ISHiK, iXinDZ, Janrevotw and Jia Leshiping added to case caption. (Text entry; no document attached.)

NEW PARTIES: JIAXIN Co.Ltd, jileijar, JINGFANG, JINTAO Co.Ltd, jirycw, JPGIF, KAILKJ, KattyBabe Co.ltd, keyiwangluo, KF Store, KS JEWELS, KTFETY, Kuo Trading Co., Ltd, LELEE shop, Life enthusiasts, Lihao medical equipment coltd, Lihui, lijingrongbaozhuangcailiao, lijinpei999, LikeYAO, LINGNA Co.Ltd, linweidianzi, linxiangqiang, Longxiang Store, loudishihuangboshangmaoyouxiangongsi, LUOKU Co.Ltd, MADNY, Magofashion, Mangofashion, MAYTINH LTD, Meili Clothing, MeiPeiShouShangMao, miehs, MINGS, MLFoif, Molla Enterprise, Mootikar, MuiexsTnew, Nansheng, NJHYcx, One trade, OTdpuo, pabo, PINAKI CREATION, Prayur Traders, PSMMZQ, PUISBXS, Puppet Toy, qianchengpingpai, qicimaoyo, qidelimaoyi, QIEhedxw, Qilu Customization Factory, QingLongXuanJiaJu, Qiu yue Xuan Wen Co., Ltd., quancaiying, QUTETN, reginala, Safar Ali Jewels, SANBAYCN, SCENT HOME, sdduchenghanshangcs, SeasonsEase, sfwv, SHAPESHE, ShenW, shenzhenmaikaisennengyuan, Shenzhenshininghuimaoyi Co. Ltd., shikacanyinguanli, ShoppingNow Co.Itd, slowlyor, Suonuo, syfs, T-buyhome, Taccostby, Taida Kitchen, THANH CONG PRINT LTD, Three grass trade, TiniDecor, Tomoaki, toraway, TRANSCOSMOS, TUWEN, Twflaqlo, UEBXS, Uinagy, ViciArt, WalGRHFR, Wang Dawn Toys and Wangxiangcao added to case caption. (Text entry; no document attached.)

NEW PARTIES: Weiyuan, WEWUOUEO, WNAGSB, wufeijie, WuHanShiYinXiang, WukONGsir, WULANLA, WuLIQna Clothing, WUYUH, Wyzesi, XiaoYong, XieJunJing, XIHAHA, Xinduolei Fashion Center, Xiujin, Xoaying, xunhangnet, xuyananchangan, xzkw, yangfeifeichangshuai, Yanhecun, YanTaiLiuZhe, YanTaiLiYiNan, yanzhikeji, Yard dream, YHETTY, Yi fragrance menswear, Yida trade, yigeyi, YinFengBeauty, Yingfanfushi, yinliting, YMBeeio, YouHouXinXiKeJiYouXianGongSi, YSfioner, Yuan Tianheng Tech Co., Ltd., YUYRY, Yuyuan Co.ltd, Zhang Culvert Toys, Zhchnlm, ZHENGFU, zhengtao, Zhongzhuoting, zhouyongzhuanqian, ZiChaoWireless, ZJSdedian, ZZF-DIY, C and Lily, Charm Unlimited Mens Clothing, Chenmeng trendy clothing, CIYUAN WIG, Dingji Art, DMTT, FXZLLQ, Hala Shy, Jimi Baby Shop, Jimibaby Cloths Shop, Kunika, love you more, Maizygote MHZ, My decorations, Nova Chic, OUBO Nippon Iekiyo, Piaoliujia WIG, Poliha Stickers, Sell a toy, SHIDAI WIG, XINMEI WIG, YUENIU WIG and ZEBRAS added to case caption. (Text entry; no document attached.)

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 12/20/2024: Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: By January 7, 2025, Plaintiff shall file a status report regarding next steps in this case. If Plaintiff intends to file a motion for default judgment, it should be filed by that date, and if Plaintiff moves for default judgment as to all Defendants, no status report need be filed. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

ATTORNEY Appearance for Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd by He Cheng

MOTION by Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd to dismiss for lack of jurisdiction

Exhibit Ex. 1 - Declaration of Baoli Yang

Exhibit Ex. 2 - Declaration of Lulu Huang

Exhibit Ex. 3 - Declaration of Xingxing Gao

Exhibit Ex. 4 - Declaration of Fangfang Song

Exhibit Ex. 5 - Declaration of Jiajian Liao

Exhibit Ex. 6 - Declaration of Jian Chen

Exhibit Ex. 7 - Declaration of Wenjie Qiao

Exhibit Ex. 8 - Declaration of Huaixi Liu

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's response to the motion to dismiss is due by January 13, 2025. No replies are permitted at this time. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MOTION by Plaintiff United States Olympic and Paralympic Committee for default judgment as to the Defendants Identified in First Amended Schedule A

MEMORANDUM by United States Olympic and Paralympic Committee in support of motion for default judgment[40]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd. Before the Court is Plaintiff's motion [40] for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, 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 January 13, 2025. 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 January 9, 2025. A hearing may be requested by filing a Request for Hearing as a separate entry on the docket. 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. Mailed notice.

CERTIFICATE of Service by Plaintiff United States Olympic and Paralympic Committee regarding set motion and R&R deadlines/hearings, set deadlines/hearings, set case scheduling order, [42]

NOTICE of Voluntary Dismissal by All Plaintiffs [CORRECTED] Notice of Dismissal 38 as to [certain] defendants

MOTION by Plaintiff United States Olympic and Paralympic Committee to stay regarding MOTION by Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd to dismiss for lack of jurisdiction [36] Plaintiffs Motion And Incorporated Memorandum In Support To Stay Defendants Motion [36], And For Leave To Conduct Jurisdictional Discovery

Exhibit 1

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no 61 HongLi Custom factory and defendant no. 124 Qilu Customization Factory

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for a stay and for jurisdictional discovery 45 is denied without prejudice. Generally, a plaintiff must be able to establish a colorable or prima facie showing of personal jurisdiction before discovery should be permitted. See In re Sheehan, 48 F.4th 513, 526 (7th Cir. 2022) (cleaned up). This approach is consistent with the case law Plaintiff cites. See e.g., HAMANN GmbH v. The Individuals, 21-cv-3591, Dkt. 53 ("The Court finds the sum of these presentations sufficient to establish a prima facie showing of personal jurisdiction. Therefore, limited jurisdictional discovery is warranted.") Given that the motion was filed on January 10, 2025 and the response brief is due today, January 13, 2025, the Court extends the deadline for Plaintiff's response to January 17, 2025. The moving Defendants' reply is due by January 24, 2025. Mailed notice.

RESPONSE by Plaintiff United States Olympic and Paralympic Committee to motion to dismiss/lack of jurisdiction, [36]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd's reply to the motion to dismiss [36] is due by January 30, 2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following Order does not apply to Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [40] is granted. 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 marks 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 $75,000 is an appropriate award of statutory damages. Enter Final Judgment Order. Mailed notice.

ENTERED DEFAULT JUDGMENT as to certain defendants Signed by the Honorable Lindsay C. Jenkins on 1/21/2025. Mailed notice.

SATISFACTION of Judgment as to [Certain] defendants

REPLY by Defendants FUCHENG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd, AIXIANG Co.Ltd to Response[50]

Exhibit Ex. 1 - Declaration of Lulu Huang

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff is given leave to file a sur-response to 55 by February 18, 2025. Mailed notice.

SURRESPONSE by United States Olympic and Paralympic Committee to Defendants Motion to Dismiss [55] for Lack of Personal Jurisdiction

Exhibit 1, filed under seal

MOTION by Plaintiff United States Olympic and Paralympic Committee for leave to file under seal

SEALED DOCUMENT by Plaintiff United States Olympic and Paralympic Committee

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court takes the pending motion to dismiss under advisement but is troubled by the declaration filed by counsel on behalf of Defendant FUCHENG in this case on January 28, 2025 at docket entry 55 -1 (declaration of Lulu Huang). A declaration for this same Defendant dated December 17, 2024 was filed in another case before this Court, Yiwu Baimei v. The Partnerships, No. 1:24-cv-11216 (dkt. 40 -2), that is signed by someone other than other than Lulu Huang. In yet another case, Hallmark v. Sch A., No. 24-cv-9543, Defendant FUCHENG, through the same counsel, filed a declaration in November 2024 signed by someone other than Lulu Huang. The Court has learned that on February 11, 2025, Defendant FUCHENG withdrew its motion to dismiss in Hallmark v. Sch. A, Case no. 24-cv-9543, which relied in part on a similar set of declarations. To put it mildly, this circumstance raises Rule 11 concerns. By February 24, 2025, counsel for the moving Defendants must file a detailed statement on the docket explaining the reasons why it withdrew its motion to dismiss in Case No. 24-cv-9543. The Court holds off, for now, on issuing a rule to show cause until after the submission is received. Mailed notice.

Statement by He Cheng in response to Court's Minute Entry [Dkt No. 60] STATEMENT by FUCHENG Co.Ltd

Exhibit Ex. 1 - Declaration 1 dated 11/28/2024

Exhibit Ex. 2 - Declaration 2 dated 12/17/2024

Exhibit Ex. 3 - Declaration 3 dated 12/25/2024

Exhibit Ex. 4 - Declaration 4 dated 1/28/2025

Exhibit Ex. 5 - Minute Entry in Case# 1:24-cv-11073

Exhibit Ex. 6 - plaintiffs evidence of test purchase in Case #1:24-cv-09543

Exhibit Ex. 7 - plaintiffs evidence of infringement in Case #1:24-cv-11216

Exhibit Ex. 8 - plaintiffs evidence of infringement in Case #1:24-cv-12015

(Exhibit Ex. 9 - Declaration of Lulu Huang with attachments of search result)

MINUTE entry before the Honorable Lindsay C. Jenkins: The information counsel filed on behalf of Defendant FUCHENG Co. Ltd. [61] raises far more questions than answers. Defendant now clarifies that "using the correct Walmart Product ID number," its records search shows that Defendant FUCHENG made two sales of Plaintiff's infringing products in the United States, one to NJ and one to MA. This information is directly contradictory to the sworn declaration counsel submitted on January 30, 2025 [Dkt. 55-1, para. 3-4 (attesting that FUCHENG has never sold, shipped, or otherwise distributed any of the accused products to the United States, and that company sales and shipping records confirm that "no order has ever been placed, and no accused product has even been shipped to the United States. ")] Defendant now asks the Court to take counsel at his word that these two sales were the only sales in the United States and that Plaintiff must be incorrect when it alleges that more units were sold. To say the least, the Court is not prepared to do so. The motion to dismiss [36] is denied without prejudice. Defendants answer is due by March 17, 2025. By March 13, 2025, the parties are to jointly propose a fact discovery schedule and if either party wishes to conduct jurisdictional discovery, it should be included in the proposed schedule to occur alongside fact discovery. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Motion for leave to file underseal 58 is granted. Mailed notice.

Joint Proposed Rule 26 Discovery Schedule by United States Olympic and Paralympic Committee

SATISFACTION of Judgment as to defendant no. 210 Charm Unlimited Mens Clothing

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court enters the following fact discovery schedule: fact and jurisdictional discovery are to proceed alongside one another. Rule 26(a)(1) disclosures are due by April 11, 2025; written discovery shall conclude by May 19, 2025; both fact and jurisdictional discovery shall be noticed in time for completion by June 18, 2025. The parties are to file a joint status report by June 9, 2025 that confirms all fact discovery and jurisdictional discovery will conclude on time and they should propose an expert discovery schedule, or they may confirm that the expert discovery schedule listed in their submission remains appropriate. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Fucheng's answer was due by March 17, 2025, but nothing was filed. Defendant Fucheng has until April 14, 2025 to file its answer. Otherwise, Plaintiff should promptly move for entry of default and default judgment under FRCP 55. Mailed notice.

ANSWER to Complaint by FUCHENG Co.Ltd

MOTION by Plaintiff United States Olympic and Paralympic Committee for default judgment as to [Certain] Defendants

MEMORANDUM by United States Olympic and Paralympic Committee in support of motion for default judgment[69]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

ANSWER to Complaint by GEXUE Co.Ltd

ANSWER to Complaint by AIXIANG Co.Ltd

ANSWER to Complaint by GUOJIJUYE Co.Ltd

ANSWER to Complaint by LINGNA Co.Ltd

ANSWER to Complaint by JINTAO Co.Ltd

ANSWER to Complaint by LUOKU Co.Ltd

ANSWER to Complaint by JIAXIN Co.Ltd

ANSWER to Complaint by JINTAO Co.Ltd

MOTION by Defendants AIXIANG Co.Ltd, GEXUE Co.Ltd, GUOJIJUYE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd for leave to file

Motion by United States Olympic and Paralympic Committee to Require Compliance with Local Rule 3.2

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by FUCHENG Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by AIXIANG Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by GEXUE Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by GUOJIJUYE Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by JIAXIN Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by JINTAO Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LINGNA Co.Ltd

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LUOKU Co.Ltd

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to require compliance with LR 3.2 80 is granted. To the extent not already completed, counsel for Defendant Nos. 6, 39, 41, 50, 72, 75, 92, 97 must file the required notification of affiliates no later than April 18, 2025. The motion for leave to file overdue answers 79 is granted. The Answers for the relevant Defendants have been filed, and the Court prefers to resolve cases on their merits. The motion for default judgment 69 is denied. Each of the answering Defendants (Nos. 6, 39, 41, 50, 72, 75, 92, 97) are subject to the fact discovery schedule imposed at docket entry 66. Mailed notice.

MOTION by Plaintiff United States Olympic and Paralympic Committee for leave to file excess pages

MOTION by Plaintiff United States Olympic and Paralympic Committee for summary judgment, a Statutory Damages Award, and, MOTION by Plaintiff United States Olympic and Paralympic Committee for permanent injunction

Local Rule 56.1(a) Statement of Material Facts as to Which There is No Genuine Issue and Which Entitles It to Summary Judgment STATEMENT by United States Olympic and Paralympic Committee

Civil Cover Sheet Table of Contents for the Exhibits Attached to Plaintiff'

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

MEMORANDUM by United States Olympic and Paralympic Committee in support of motion for summary judgment, motion for permanent injunction, [91] as to the Defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court was not anticipating summary judgment motions until after the close of fact and expert discovery, particularly given that the impacted Defendants only recently answered and fact discovery only recently began [see docket entry 66]. The filing did not propose an agreed briefing schedule as required by the Court's standing order. Counsel for Plaintiff and the impacted Defendants are to confer and file a joint statement on the docket by April 30, 2025 that sets forth Defendants' position on whether discovery is necessary for its response to the motion, and if not, the parties proposed dates for a response and reply brief. The filing must include a statement from Plaintiff identifying which Defendants remain in the case aside from the Defendants impacted by the motion, that is aside from Defendant Nos. 6 AIXIANG Co. Ltd, 39 FUCHENG Co. Ltd, 41 GEXUE Co.Ltd, 50 GUOJIJUYE Co. Ltd, 72 JIAXIN Co. Ltd, 75 JINTAO Co. Ltd, 92 LINGNA Co. Ltd, and 97 LUOKU Co. Ltd. Mailed notice

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for excess pages [90] is granted. Mailed notice.

JOINT STATEMENT by United States Olympic and Paralympic Committee Pursuant to Minute Entry [94]

MINUTE entry before the Honorable Lindsay C. Jenkins: The Cheng Defendants believe that a limited amount of discovery is necessary to respond to the motion, which has been requested by a subpoena. Defendants' response to the motion for summary judgment is due June 17, 2025; Plaintiff's reply is due by July 8, 2025. Mailed notice.

SATISFACTION of Judgment as to [certain] defendants

STATUS Report JOINT Status Report Pursuant to [66] by United States Olympic and Paralympic Committee

MINUTE entry before the Honorable Lindsay C. Jenkins: The parties report that fact discovery will close on time. Defendants' response to the motion for summary judgment remains due by June 17, 2025 and Plaintiff's reply remains due by July 8, 2025. The court imposes the following expert discovery schedule as proposed by docket entry 64 : Plaintiff's expert disclosures are due by July 11, 2025; Defendants' expert disclosures are due by July 25, 2025; Plaintiff's expert report(s) pursuant to Rule 26(a)(2) due by August 22, 2025; Defendants' expert report(s) pursuant to Rule 26(a)(2) due by September 19, 2025; all expert depositions are to be completed by October 24, 2025. A status report as to the close of expert discovery is due by October 10, 2025. Mailed notice.

MOTION by Defendants AIXIANG Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd for extension of time to file response/reply as to motion for summary judgment, motion for permanent injunction, [91] and to extend fact and jurisdictional discovery deadline [Jointly]

MINUTE entry before the Honorable Lindsay C. Jenkins: The parties now say that fact discovery will not close on time and a one-week extension of the deadline is needed so that an overseas deposition can occur. The fact discovery deadline is extended to June 25, 2025, but only for the purpose of the Rule 30(b)(6) designees for Defendant set for tomorrow, June 19. Defendants' response to the motion for summary judgment is now due by June 24, 2025 and any reply is due by July 15, 2025. The expert discovery deadlines set by docket entry 100 stand. Mailed notice.

MOTION by Plaintiff United States Olympic and Paralympic Committee to approve consent judgment JOINT

RESPONSE by AIXIANG Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd to MOTION by Plaintiff United States Olympic and Paralympic Committee for summary judgment, a Statutory Damages Award, and MOTION by Plaintiff United States Olympic and Paralympic Committee for permanent injunction [91]

DECLARATION of He Cheng regarding response to motion, [104]

Exhibit Ex.1- AIXIANG Co.Ltd's Response to Plaintiff's first set of in

Exhibit Ex.2- FUCHENG Co.Ltd's Response to Plaintiff's first set of in

Exhibit Ex.3- GEXUE Co.Ltd's Response to Plaintiff's first set of inte

Exhibit Ex.4- JIAXIN Co.Ltd's Response to Plaintiff's first set of int

Exhibit Ex.5- JINTAO Co.Ltd's Response to Plaintiff's first set of int

Exhibit Ex.6- LINGNA Co.Ltd's Response to Plaintiff's first set of int

Exhibit Ex.7- LUOKU Co.Ltd's Response to Plaintiff's first set of inte

Exhibit Ex. 8 - Original Walmart sales data spreadsheet

Exhibit Ex. 9 - Condensed table of sales data

Exhibit Ex. 10 - AIXIANG Co.Ltd's relevant document production

Exhibit Ex. 11 - FUCHENG Co.Ltd's relevant document production

Exhibit Ex. 12 - GEXUE Co.Ltd's relevant document production

Exhibit Ex. 13 - JIAXIN Co.Ltd's relevant document production

Exhibit Ex. 14 - JINTAO Co.Ltd's relevant document production

Exhibit Ex. 15 - LINGNA Co.Ltd's relevant document production

Exhibit Ex. 16 - LUOKU Co.Ltd's relevant document production

RESPONSE by Defendants AIXIANG Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd to statement, 92 Response to Plaintiffs Local Rule 56.1 Statement of Material Facts

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to approve the consent judgment 103 is granted. Separate order to issue. Mailed notice.

ENTERED CONSENT JUDGMENT AS TO DEFENDANT GUOJIJUYE CO.LTD Signed by the Honorable Lindsay C. Jenkins on 6/25/2025. Mailed notice.

MOTION by Defendants AIXIANG Co.Ltd, JIAXIN Co.Ltd, LUOKU Co.Ltd, JINTAO Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, LINGNA Co.Ltd to dismiss for lack of jurisdiction [Renewed]

Exhibit Ex. 1 - Declaration of Cheng

Exhibit Attachment 1 to Decl. of Cheng - Subpoena

(Exhibit Attachment 2 to Decl. of Cheng - Defendants' Walmart Seller Center Search)

MINUTE entry before the Honorable Lindsay C. Jenkins: Certain Defendants have renewed their motion to dismiss for lack of jurisdiction, which the court previously denied without prejudice to renewal including for the purpose of conducting jurisdictional discovery 62. The court's obligation is to address jurisdictional questions first, so the July 15, 2025 reply date for summary judgment is stricken and will be reset, if necessary. Plaintiff's response to the motion to dismiss is due by July 10, 2025 and any reply is due by July 17, 2025. Mailed notice.

RESPONSE by United States Olympic and Paralympic Committeein Opposition to MOTION by Defendants AIXIANG Co.Ltd, JIAXIN Co.Ltd, LUOKU Co.Ltd, JINTAO Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, LINGNA Co.Ltd to dismiss for lack of jurisdiction [Renewed] 109

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

(Exhibit 9)

REPLY by AIXIANG Co.Ltd, FUCHENG Co.Ltd, GEXUE Co.Ltd, JIAXIN Co.Ltd, JINTAO Co.Ltd, LINGNA Co.Ltd, LUOKU Co.Ltd to response in opposition to motion, 111

MINUTE entry before the Honorable Lindsay C. Jenkins: The remaining Defendants AIXIANG Co. Ltd, JIAXIN Co. Ltd, LUOKU Co. Ltd, JINTAO Co. Ltd, FUCHENG Co. Ltd, GEXUE Co. Ltd, LINGNA Co. Ltd's renewed motion to dismiss [109] is granted. See attached order for further details. The preliminary injunction order is vacated and the claims against the remaining Defendants are dismissed without prejudice to Plaintiff pursuing the relief it seeks in the appropriate forum. The motion for summary judgement [91] is denied as moot. Civil case terminated. Mailed notice.

ORDER written by the Honorable Lindsay C. Jenkins on 7/21/2025. Mailed notice.

ENTERED JUDGMENT on 7/21/2025. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 7/21/2025 to Patent Trademark Office, Alexandria VA

MOTION by Plaintiff United States Olympic and Paralympic Committee for reconsideration

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for reconsideration 117 is denied. In ruling on Certain Defendants' renewed motion to dismiss, the court fulfilled its obligation to consider whether a transfer was appropriate. [See Dkt. 114 at 3.] The court concluded that a transfer to the Southern District of Florida was not necessary under 28 USC 1631 in the interests of justice because there was no impediment to refiling. That makes this case different than Alison Friend v. the Partnerships et al., No. 25-cv-4313, Dkt. 59 (N.D. Ill. July 30, 2025) where the court had not performed an analysis under the transfer statute in its order dismissing that case. Here, the court considered whether a transfer of the action was appropriate and concluded that it was not. [Dkt. 114 at 3 (noting that the interests of justice did not require transfer even if doing so would preserve the status quo because there was no bar to refiling).] That analysis applies equally to a transfer under 28 USC § 1404(a), which also permits a transfer in the interests of justice. Finally, the court appreciates that Plaintiff raises several jurisdictional gamesmanship arguments as a reason to consider transferring the case, namely because Defendants designated Mengke Liu as the Rule 30(b)(6) corporate witness during discovery even though he lacked firsthand knowledge of Defendants' operations and "offered only scripted, generalized responses, preventing any meaningful inquiry into each Defendant's jurisdictional contacts." [Dkt. 117 at 2-3.] But the remedy for that would have been to file a motion to compel while jurisdictional discovery was ongoing, which Plaintiff elected not to do. Given this posture, the court declines to reconsider its prior ruling. Mailed notice.

SATISFACTION of Judgment as to defendant no. 49 guangzhouruixinyikejiyouxiangongsi and defendant no. 224 OUBO Nippon Iekiyo