2024-cv-13082

COMPLAINT filed by Sen Zhang; Filing fee $ 405, receipt number AILNDC-22867763.

Exhibit 2

Exhibit 3

(Exhibit 4)

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff Sen Zhang Exhibit 1: Copyright Registration regarding complaint 1

SEALED DOCUMENT by Plaintiff Sen Zhang Schedule A

ATTORNEY Appearance for Plaintiff Sen Zhang by Abby Marie Neu

ATTORNEY Appearance for Plaintiff Sen Zhang by Shengmao Mu

ATTORNEY Appearance for Plaintiff Sen Zhang by Keaton David Smith

ATTORNEY Appearance for Plaintiff Sen Zhang by Michael Mitchell

MOTION by Plaintiff Sen Zhang for leave to file UNDER SEAL

CASE ASSIGNED to the Honorable Charles P. Kocoras. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. Case assignment: Random assignment. (Civil Category 3). (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 copyright report to Registrar, Washington DC

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's motion for leave to file under seal 9 is granted. Mailed notice

MOTION by Plaintiff Sen Zhang for temporary restraining order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sen Zhang in support of motion for temporary restraining order 12

DECLARATION of Sen Zhang regarding memorandum in support of motion 13

SEALED EXHIBIT by Plaintiff Sen Zhang Exhibit 1 regarding declaration 14

SEALED EXHIBIT by Plaintiff Sen Zhang Exhibit 2 regarding declaration 14

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

MEMORANDUM by Sen Zhang in support of motion for miscellaneous relief 17

DECLARATION of Shengmao Mu regarding motion for miscellaneous relief 17, motion for temporary restraining order 12

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

NOTICE of Motion by Keaton David Smith for presentment of motion for miscellaneous relief 17, motion for temporary restraining order 12 before Honorable Charles P. Kocoras on 1/7/2025 at 09:50 AM.

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.

MINUTE entry before the Honorable Charles P. Kocoras:Plaintiff's ex parte motion for temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 12 and Plaintiff's motion for electronic service of process 17 are GRANTED. Presentment hearing noticed for 1/7/2025 is stricken with no appearance necessary. Enter sealed temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable Charles P. Kocoras on 12/31/2024. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to Complaint (Text entry; no document attached.)

MOTION by Plaintiff Sen Zhang to Extend the Temporary Restraining Order

MEMORANDUM by Sen Zhang in support of motion for miscellaneous relief 24

(Declaration of Shengmao Mu)

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to extend the TRO 24 is granted. The 12/31/2024 TRO 22 is extended to 1/28/2025. Mailed notice.

SURETY BOND in the amount of $ 10,000.00 posted by Sen Zhang. (Document not imaged) (Received at the Intake Counter on 01/10/2025.)

MOTION by Plaintiff Sen Zhang for preliminary injunction

EXHIBIT by Plaintiff Sen Zhang Exhibit A regarding MOTION by Plaintiff Sen Zhang for preliminary injunction [28]

MEMORANDUM by Sen Zhang in support of motion for preliminary injunction[28]

Declaration of Shengmao Mu

NOTICE of Motion by Keaton David Smith for presentment of motion for preliminary injunction[28] before Honorable Charles P. Kocoras on 1/28/2025 at 09:50 AM.

SUMMONS Returned Executed by Sen Zhang as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to Complaint on 1/22/2025, answer due 2/12/2025.

Declaration of Shengmao Mu

Exhibit A

ATTORNEY Appearance for Defendants ETJOY, Oyisca, MMstyle, Mrmian by Adam Edward Urbanczyk

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Preliminary Injunction [28] is granted. The Clerk is directed to unseal Exhibit 1 to Plaintiff's Complaint [3], Schedule A to the Complaint [4], and the TRO [22]. Plaintiff is instructed to add all defendant names to the docket within three (3) business days. A status report is due on 2/24/2025. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Charles P. Kocoras on 1/24/2025. Mailed notice

NEW PARTIES: 2LB Depot, Ailiqiqi, Aimsa Direct, ArtSo Direct, Atufsuat, Auhoahsil Direct, Aungfonlr, baoshou, Cadynn, DAPESUOM Direct, Dteck Inc, Fashion Vava, Futuregrace, HeartOrigin Direct, Hostline, iDonzon, Ieusew, IMAYONDIA, Jakago, jiaodiren, JIAXIUFEN USA, Lahome, Lamcase Direct, LRCXL Dealer, LUOLNH, Mektron, naruichao, Niniubye, Nipichsha, Rouidr, saicok, saiersi, Shenzhen luxinhe Technology Co., Ltd., Stones in the rain, Sunflower Sun, TENJUN STORE, Theoneer, ToLuLu, yuanhuili, YUSE Co., Ltd and YYU-DESIGN added to case caption. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Sen Zhang as to certain Defendants

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff filed a notice of voluntary dismissal [36] as to certain defendants. Accordingly, all claims against the defendants listed in the notice are dismissed without prejudice. Mailed notice

NOTICE of Voluntary Dismissal by Sen Zhang as to a certain Defendant

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal [38], all claims against Defendant No. 11, Dteck Inc, are dismissed without prejudice. Mailed notice

MOTION by Defendants Oyisca, MMstyle, Mrmian, ETJOY to vacate preliminary injunction[35]

Exhibit 1

Declaration of Jiaowei Huang

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Oyisca, MMstyle, Mrmian, and ETJOY's motion to vacate the preliminary injunction [40] is entered and briefed as follows: response is due by 3/5/2025; reply is due by 3/19/2025. Court will rule by mail. Mailed notice.

ATTORNEY Appearance for Defendants Oyisca, MMstyle, Mrmian, ETJOY by Brian Swift

ANSWER to Complaint by Oyisca, MMstyle, Mrmian, ETJOY

NOTICE of Voluntary Dismissal by Sen Zhang as to certain Defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal [44], all claims against the Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

MOTION by Plaintiff Sen Zhang for entry of default, MOTION by Plaintiff Sen Zhang for default judgment as to all Defendants with the Exception of Certain Defendants

Exhibit A

MEMORANDUM by Sen Zhang in support of motion for entry of default, motion for default judgment[46]

DECLARATION of Shengmao Mu regarding memorandum in support of motion[47]

NOTICE of Motion by Keaton David Smith for presentment of motion for entry of default, motion for default judgment[46] before Honorable Charles P. Kocoras on 2/18/2025 at 09:50 AM.

CORRECTED NOTICE of Motion by Keaton David Smith for presentment of motion for entry of default, motion for default judgment[46] before Honorable Charles P. Kocoras on 2/25/2025 at 09:50 AM.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion for default and default judgment [46] is granted. Enter default judgment order. Plaintiff is to file a status report regarding what defendants remain in the case, the status of settlement negotiations, and proposed next steps in the case on 3/21/25. Presentment hearing scheduled on 2/25/2025 is stricken. Mailed notice.

DEFAULT JUDGMENT ORDER Signed by the Honorable Charles P. Kocoras on 2/19/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Sen Zhang as to certain Defendants

NOTICE of Voluntary Dismissal by Sen Zhang as to certain Defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with Plaintiff's notice of voluntary dismissal [54], all claims against Defendants listed in the notice, are dismissed without prejudice. Mailed notice.

RESPONSE by Sen Zhangin Opposition to MOTION by Defendants Oyisca, MMstyle, Mrmian, ETJOY to vacate preliminary injunction[35] [40]

Exhibit 1

Exhibit 2

Declaration of Shengmao Mu

Exhibit A

FULL SATISFACTION of Judgment as to certain Defendants

ATTORNEY Appearance for Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi by Jiyuan Zhang

MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to vacate Default Judgment[52]

Declaration Zeng

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, and saiersi's motion to vacate the default judgment [59] is entered and briefed as follows: response is due by 3/28/2025; reply is due by 4/11/2025. Court will rule by mail. Mailed notice.

ATTORNEY Appearance for Defendant yuanhuili by Longhao Wang

FULL SATISFACTION of Judgment as to a certain Defendant

MOTION by Defendants ETJOY, MMstyle, Mrmian, Oyisca for extension of time to complete discovery (expedited)

OBJECTIONS by Sen Zhang to MOTION by Defendants ETJOY, MMstyle, Mrmian, Oyisca for extension of time to complete discovery (expedited) [63]

Declaration Mu

Exhibit 1

MOTION by Defendant yuanhuili to set aside default

Declaration by Liqing Liang

Exhibit A (order in Case No. 24-cv-06834)

MINUTE entry before the Honorable Charles P. Kocoras: Defendant yuanhuili's Motion to Vacate Default Judgment [65] is entered and briefed as follows: response is due by 4/8/2025; reply is due by 4/22/2025. Court will rule by mail. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Oyisca, MMstyle, mrmian, and ETJOY's motion for extension of time [63] is granted. Defendants' discovery responses are due by 3/28/2025. Mailed notice.

REPLY by ETJOY, MMstyle, Mrmian, Oyisca to response in opposition to motion, [56]

STATUS Report by Sen Zhang

MINUTE entry before the Honorable Charles P. Kocoras: The Court reviewed Plaintiff's status report [69]. An updated report regarding settlement, remaining defendants, and possibility of resolution of any pending motions is due on 5/9/2025. Mailed notice.

MOTION by Plaintiff Sen Zhang for extension of time to file response/reply as to motion to vacate[59] Unopposed

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's unopposed motion for extension of time [71] is granted. Plaintiff's response to Defendants' motion to vacate [59] is now due by 4/18/2025, and Defendants' reply is now due 5/2/2025. Mailed notice.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by ETJOY, MMstyle, Mrmian, Oyisca

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant yuanhuili (Def. #43)

FULL SATISFACTION of Judgment as to a certain Defendant

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Oyisca, MMstyle, mrmian, and ETJOY's Motion to Vacate the Preliminary Injunction [40] is denied without prejudice. An updated joint status report regarding the progress of discovery and settlement negotiations, remaining defendants, and possibility of resolution of any pending motions remains due on 5/9/2025. See Statement for details. Mailed notice.

ORDER Signed by the Honorable Charles P. Kocoras on 4/8/2025. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: In light of the stipulation of dismissal as to Defendant yuanhuili [74], Defendant yuanhuili's motion to vacate [65] is terminated as moot. Mailed notice.

MOTION by Plaintiff Sen Zhang for extension of time to file response/reply as to motion to vacate[59] Joint

MINUTE entry before the Honorable Charles P. Kocoras: Joint motion for extension of time [79] is granted. Plaintiff's response to Defendants' motion to vacate [59] is now due 5/9/2025; Defendants' reply in support is now due 5/23/2025. Mailed notice.

RESPONSE by Sen Zhangin Opposition to MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to vacate Default Judgment[52] [59]

DECLARATION of Keaton Smith regarding response in opposition to motion[81]

Exhibit 1

MINUTE entry before the Honorable Charles P. Kocoras: A status report was not filed on 5/9/2025, as previously ordered [76]. The status report is now due by 5/19/2025. Mailed notice.

STATUS Report by Sen Zhang

STIPULATION of Dismissal Joint as to certain defendants

MINUTE entry before the Honorable Charles P. Kocoras: In accordance with the Joint Stipulation of Dismissal [85], all claims against Defendants ETJOY (Def. #12), MMstyle (Def. #28), mrmian (Def. #29), and Oyisca (Def. #33) are dismissed with prejudice. Mailed notice.

REPLY by Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to response in opposition to motion[81]

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, and saiersi's Motion to Vacate the Default Judgment 59 is denied. See Statement for details. Mailed notice.

ORDER Signed by the Honorable Charles P. Kocoras on 6/10/2025. Mailed notice.

MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi for reconsideration regarding order[89]

DECLARATION of Haisen Zeng regarding motion for reconsideration[90]

Exhibit 1. Purchase Link

Exhibit 2. Purchase Link

Exhibit 3. Purchase Link

DECLARATION of Jianguo Dai regarding motion for reconsideration[90]

Exhibit 1. CR registration

Exhibit 2. Image

DECLARATION of Jiyuan Zhang regarding motion for reconsideration[90]

Exhibit 1. Article

Exhibit 2. News

Exhibit 3. News

Exhibit 4. Article

Exhibit 5. Judge John F. Kness' Order

Exhibit 6. Order deny PI (N.D.I.L. 24-06834. Dkt 96)

MINUTE entry before the Honorable Charles P. Kocoras: Motion by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, and saiersi for Reconsideration [90] is entered and briefed as follows: response is due by 7/30/2025; reply is due by 8/13/2025. Court will rule by mail. Mailed notice.

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

RESPONSE by Sen Zhangin Opposition to MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi for reconsideration regarding order[89] [90]

Declaration Mu

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

REPLY by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to motion for reconsideration[90]

Declaration of JZ w/ Ex A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi

SUPPLEMENT to motion for reconsideration[90] New Order from 25-cv-02937 (N.D.I.L.) (Dkt. 22)

Exhibit Court Order

MOTION by Plaintiff Sen Zhang for leave to file surreply to Dkt. Nos. 97 and 98

MOTION by Plaintiff Sen Zhang for leave to file surreply to Dkt. Nos. 97 and 99

SUR-REPLY by Plaintiff Sen Zhang to supplement[99], reply[97]

MOTION by Plaintiff Sen Zhang to strike MOTION by Plaintiff Sen Zhang for leave to file surreply to Dkt. Nos. 97 and 98 [100]

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's motion to strike its first-filed motion to strike [103] is granted. The first-filed motion to strike [100] is stricken. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Plaintiff's Motion for Leave to File Surreply re Docket No. 97 and Motion to Strike Docket No. 99 [101] is granted in part. The Court will consider Plaintiff's surreply [102] in assessing Defendants' motion to reconsider [90]. No further briefing from any of the parties will be permitted. However, although it was improperly filed with leave of Court, the Court will not strike Defendants' "supplement" to their reply [99] at this time, given that the Court is already aware of Judge Kness's recent order. Mailed notice.

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, and saiersi's Motion to Reconsider [90] is granted. The Default Judgment [52] entered against Defendants is VACATED. Defendants shall answer Plaintiff's complaint by 9/24/2025. This matter is hereby referred to the Magistrate Judge for discovery supervision and a settlement conference. See Statement for details. Mailed notice.

ORDER Signed by the Honorable Charles P. Kocoras on 9/2/2025. Mailed notice.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Keri L. Holleb Hotaling for the purpose of holding proceedings related to: discovery supervision and settlement conference, if needed. Mailed notice.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: This matter has been referred to Judge Holleb Hotaling for discovery management and settlement. Since the parties' last status report was filed in May [Dkt. 84], the parties are to file an updated status report on 9/10/2025 including a general status of any discovery engaged in to date, proposing a fact discovery schedule, including a general status of the remaining parties' settlement discussions to date, and indicate each party's willingness to engage in a settlement conference at this juncture.

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The parties failed to file their 9/10/2025 joint status report as ordered [Dkt. 109]. The parties shall file that report by 9/23/2025 with an explanation for its tardiness.

STATUS Report Joint by Sen Zhang Presented before Magistrate Judge

MINUTE entry before the Honorable Keri L. Holleb Hotaling: The parties' joint status report [Dkt. 111] (which does not include an explanation for its tardiness, as ordered [Dkt. 110]), appears to indicate that discovery has been stalled in this case for 2 months. That report also indicates the parties "have begun to engage in settlement discussions but have yet to exchange initial offers" which is perplexing to the Court as it cannot understand how any settlement discussions are under way without any initial demand/offer. The Court hereby sets a telephonic status on this matter on 10/7/2025 at 11:00 a.m. CT. The call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by Atufsuat, Rouidr, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, saiersi against Sen Zhang. by Atufsuat, Rouidr, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, saiersi

MINUTE entry before the Honorable Keri L. Holleb Hotaling: Defendants' counsel failed to appear at the telephonic status hearing scheduled for 10/7/2025 and could not be reached. The telephonic status hearing set for 10/7/2025 is hereby stricken and reset to 11/4/2025 at 10:30 a.m. At least one counsel for each party who has an appearance on file on the docket is REQUIRED to appear telephonically for this hearing. Court may schedule future hearings in person if parties continue to fail to appear for telephonic hearings. The call in information is 855-244-8681, and the participant access code is 2315 0911 461#.

MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to vacate preliminary injunction[35] Presented before District Judge

DECLARATION of Zeng regarding motion to vacate[115]

MINUTE entry before the Honorable Charles P. Kocoras: Defendants' motion to vacate the preliminary injunction [115] is not a motion submitted by counsel but a declaration of Haisen Zeng. The Court presumes this declaration was intended to be an exhibit to Defendants' motion, not the motion itself. Defendants are instructed to re-file their motion to vacate with the proper documents. Mailed notice.

MOTION by Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, saiersi to vacate order on motion to vacate, text entry, [117] revised MTD Presented before District Judge

MINUTE entry before the Honorable Charles P. Kocoras: Defendants Atufsuat, Auhoahsil Direct, DAPESUOM Direct, Niniubye, Nipichsha, Rouidr, and saiersi's Motion to Vacate or Modify the Preliminary Injunction [118] is entered and will be briefed as follows: response is due by 10/31/2025; reply is due by 11/7/2025. The Court will rule by mail. Mailed notice.