2025-cv-04530

COMPLAINT filed by RC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23399547.

Schedule A

Ex.1

Ex.2

Ex.3

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff RC by James Edward Judge

MOTION by Plaintiff RC for leave to file documents under seal

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable M. David Weisman. Case assignment: Random assignment. (Civil Category 1).

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.

SUMMONS - ERROR UNPROCESSED due to old summons form version used. Please resubmit using New Summons Electronic Issuance Version https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_online/ao440e.pdf

NEW PARTIES: Hebei Jiubai Technology Co., Ltd., Linwell Shenzhen Technology Co., Ltd., Yiwu Zuofu Import And Export Co., Ltd. and CX-52 Store added to case caption.

NEW PARTIES: Best Seller Shop Store, Top-Handicraft Dropshipping Store, ROCAL Store, Finding Happiness Life Store, BrownAugust Store, BUFAZO Store, JINYH Store, WUJIE Garden Store, HuiSuYiTong Garden Store, Shop1103053828 Store, Pet Mall Store, Pro Hiker Store, Pro Houseware Store, 3C-Top Store, Home Cool Store, Smart Consumer Electronics Store, Electronic Industry Store, 3C Digital Tech Club Store Store, Outdoor Camping4 Store, Etmakit Directly Store, Beisidiyou002 Store, PC Peripheral Store, Shop1103755325 Store, E-commerce Digital Store, Handbag Dropshipping Store, MOJOYCE Speciality Store, Outdoor SuperTop Store, Audio Video Equipment Store, Shop1103835496 Store, Shop1103877539 Store and Intelligent Electronic Store added to case caption.

NEW PARTIES: KANOKO Store, Tina Sweethome Store, Shop1104198299 Store, Shop1104301228 Store and Duratoolstore-US added to case caption.

NEW PARTIES: MUUIHRN Store, Crisandy, xiaowangshu1, Safe North, Ismat Trading, Eseven777, BETTER shop one, CHENGFUSEN and GUIMU added to case caption.

Terminating Shop1103835496 Store

Terminating MOJOYCE Speciality Store

NEW PARTIES: YJ CREA LAB, WOWOS BOOTH, Enhan, guangzhoulikaishangmao, Raised Living, finest brand, Fximey, Fangge, PuTianShiChengXiangQuLinChenFeiBaiHuoShangDian, chengyinshanghang, KALKISIM STORE, Chang Bigg, wu wei mao yi, Nokiils, ANFENGLI, LBDONDIN, suizhoushichengyunmiaodianzishangwuyouxiangongsi, Apalie-us, NCCWAN, Surprise Store USA, Topetitud, CHENG SHI YE GUANG, runchengshuini, Huangshengtiyu, shadow rose, ying ka, Juyuanya, HLMOptimo SELECT, Young Nature Life, PL International of US and Muxhel added to case caption.

NEW PARTIES: mlhpeak, NESKAL STORE, bestlinkstore, bigbigphoneseller, cozynestlife, gloudjoyshop, YOKOSTORE, Lamacimi Store, MASUOKASTORE, meganetshop, MIRAISTYLESTORE, Myre_link2015, NoriakiStore, perfect_potata, vendozway, youfeelathome, GT Life Power, HR CO.,LTD, HYEASTR STORE, NingXiaKaiBoKeJi, BITOUSHI, ADHO, SGTL SHOP, putianshuanUKaishop, Lejing e-commerce, shijinshazunshang, DY168, taisen, N-Market and HDN-168 added to case caption.

NEW PARTIES: MOJOYCE Speciality Store and Shop1103835496 Store added to case caption.

SEALED DOCUMENT by Plaintiff RC Unredacted Complaint

MAILED Patent Request Letter to Plaintiff's counsel.

MINUTE entry before the Honorable John Robert Blakey: In this patent infringement case, Plaintiff seeks to sue 314 separate defendants for infringement of its trademarks, copyrights, and patent, see [5]. But such joinder appears to run afoul of 35 U.S.C. § 299, which provides that "parties that are accused infringers may be joined in one action as defendants. only if-- (1) any right to relief is asserted against the parties jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences relating to the making, using, importing into the United States, offering for sale, or selling of the same accused product or process; and (2) questions of fact common to all defendants or counterclaim defendants will arise in the action." Id. § 299(a). The statute specifically provides that "accused infringers may not be joined in one action as defendants. based solely on allegations that they each have infringed the patent or patents in suit." Id. § 299(b). Along the same lines, joinder of multiple defendants in a single trademark or copyright infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). In this regard, Plaintiff's complaint, which lumps all Defendants together, alleges that "the Defendant Internet Stores share unique identifiers, such as similar design elements of the infringing products offered for sale and, on information and belief, these similarities suggest that the Defendant Internet Stores share common manufacturing sources, thus establishing that the Defendants' counterfeiting and infringing operations arise out of the same transaction, occurrence, or series of transactions or occurrences." [5] at 4. Plaintiff also alleges that the "Defendant Internet Stores share unique identifiers, such as common design elements, the same or similar counterfeit products that they offer for sale, similar counterfeit product descriptions, the same or substantially similar shopping cart platforms, accepted payment methods, and check-out methods, lack of contact information, and identically or similarly priced counterfeit products and volume sale discounts. As such, the Defendant Internet Stores establish a logical relationship between them and suggest that Defendants' illegal operations arise out of the same transaction or occurrence." Id. at 18. But these allegations remain conclusory and unsupported; what's more, the conclusion does not necessarily follow from the alleged facts; it is equally possible that each online retailer set up shop in the same or similar manner. See, e.g., Estee Lauder Cosms. Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, 334 F.R.D. 182, 188-89 (N.D. Ill. 2020). Plaintiff also alleges that the allegedly "infringing products for sale in Defendant Internet Stores bear similarities and indicia of being related to one another, suggesting that the infringing products were manufactured by and come from a common source and that, upon information and belief, Defendants are interrelated." Id. at 24. But this allegation also remains conclusory and unsupported. The Court accordingly finds that Plaintiff may not proceed on the current complaint [1], [5] and dismisses it without prejudice. If Plaintiff can, consistent with its obligations under Rule 11, amend its complaint to support the joinder of the identified Defendants in this single action, it may do so by 5/30/25. The Court grants Plaintiff's motion to seal [4], and Plaintiff may file its amended complaint under seal as well. If Plaintiff declines to amend, the Court will dismiss this case. Mailed notice.

ATTORNEY Appearance for Plaintiff RC by Ying Chen

ATTORNEY Appearance for Plaintiff RC by Zareefa Burki Flener

Redacted AMENDED complaint by RC against The Partnerships and Unincorporated Associations Identified in Schedule A

Schedule A

Ex.1

SEALED DOCUMENT by Plaintiff RC Unredacted Amended Complaint

MOTION by Plaintiff RC for leave to file excess pages

SEALED MOTION by Plaintiff RC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Alternative Service

SEALED DOCUMENT by Plaintiff RC Memorandum in Support of Joinder

MINUTE entry before the Honorable John Robert Blakey: Plaintiff has filed an amended complaint alleging patent, trademark, and copyright infringement against 110 separate defendants. See [11]. As previously explained, joinder of multiple defendants in a patent infringement case remains appropriate "only if-- (1) any right to relief is asserted against the parties jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences relating to the making, using, importing into the United States, offering for sale, or selling of the same accused product or process; and (2) questions of fact common to all defendants or counterclaim defendants will arise in the action." 35 U.S.C. § 299(a). Similarly, joinder of multiple defendants in a single trademark or copyright infringement action remains appropriate only if the claims against the defendants are asserted "with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences," and a common question of law or fact exists as to all defendants. Fed. R. Civ. P. 20(a)(2)(A)-(B). To this end, Plaintiff's amended complaint alleges that the Defendant Internet Stores "share unique identifiers, such as common design elements, the same or similar counterfeit products that they offer for sale, similar counterfeit product descriptions, the same or substantially similar shopping cart platforms, accepted payment methods, and check-out methods, lack of contact information, and identically or similarly priced counterfeit products and volume sale discounts. As such, the Defendant Internet Stores establish a logical relationship between them and suggest that Defendants' illegal operations arise out of the same transaction or occurrence." [11] 18. Plaintiff further alleges that the "infringing products for sale in Defendant Internet Stores bear similarities and indicia of being related to one another, suggesting that the infringing products were manufactured by and come from a common source and that, upon information and belief, Defendants are interrelated." Id. 24. Along with its amended complaint, Plaintiff filed a memorandum in support of joinder, which concedes that "not every Defendant infringes each specific type of intellectual property asserted by Plaintiff," but argues that Defendants actions nonetheless "are clearly interrelated" as evidenced by "the identical nature of the products and packaging, the repeated use of the same photographs, and the fact that all Defendants' shipments include the same instruction manual, strongly suggesting a common source for the knock-off products." [14] at 2. Plaintiff submitted a declaration from its chairman and secretary (supported with documentary evidence) indicating that "100% of the counterfeit products offered and sold by the defendants are identical to the products manufactured by Defendant Linwell (Shenzhen) Technology Co., Ltd. (Doe #2)"; all of the defendants' shipments "include the same instruction manual, which is different from the one used by Plaintiff"; and many of the defendants share packaging designs or components. [14-1] 5. This evidence suffices to support the joinder of all named defendants in this single lawsuit, and Plaintiff may thus proceed on its amended complaint [11]. The Court grants Plaintiff's motion for leave to file excess pages [12] but denies without prejudice Plaintiff's motion for entry of a temporary restraining order [13] because Plaintiff failed to notice the motion for presentment and failed to submit a proposed order, as required by this Court's standing orders. Mailed notice.

MOTION by Plaintiff RC for leave to file documents under seal

SEALED MOTION by Plaintiff RC for Entry of a Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Alternative Service Renewed Motion

NOTICE of Motion by James Edward Judge for presentment of motion for leave to file[16], Sealed motion, [17] before Honorable John Robert Blakey on 6/11/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motion for leave to file documents under seal [16] but once again denies Plaintiff's motion for entry of a temporary restraining order [17] based upon Plaintiff's failure to submit a proposed order with its motion, The 6/11/25 Notice of Motion date is stricken as to all motions. Mailed notice.

MOTION by Plaintiff RC for temporary restraining order Renewed Motion for Temporary Restraining Order

NOTICE of Motion by James Edward Judge for presentment of motion for temporary restraining order[20] before Honorable John Robert Blakey on 6/18/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants in part Plaintiff's ex parte motion for entry of a temporary restraining order [13]. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 6/26/25. The 6/18/25 Notice of Motion date is stricken. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable John Robert Blakey on 6/12/2025. Mailed notice.

SURETY BOND in the amount of $10,000 posted by Rinne Corp. (Document not scanned).

MOTION by Plaintiff RC to Extend Temporary Restraining Order

NOTICE of Motion by James Edward Judge for presentment of motion for miscellaneous relief[25] before Honorable John Robert Blakey on 6/25/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motion to extend the temporary restraining order entered 6/12/25 [25] and strike the 6/25/25 Notice of Motion Date. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 7/10/25. Mailed notice. (jcc,)

SUMMONS Submitted (Court Participant) for defendant(s) by Plaintiff RC

SUMMONS Submitted (Court Participant) for defendant(s) by Plaintiff RC

SUMMONS Issued (Court Participant) as to Defendant Hebei Jiubai Technology Co., Ltd. and all other defendants identified in the Complaint.

MOTION by Plaintiff RC for preliminary injunction as to Certain Defendants

Ex. 1

MEMORANDUM by RC in support of motion for preliminary injunction[31]

Declaration of James E. Judge

NOTICE of Motion by James Edward Judge for presentment of motion for preliminary injunction[31] before Honorable John Robert Blakey on 7/9/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court denies without prejudice Plaintiff's motion for preliminary injunction 31 because it fails to comply with this Court's standing order concerning noticed motions. The 7/9/25 Notice of Motion date is stricken. Mailed notice.

MOTION by Plaintiff RC for preliminary injunction Renewed Motion for Preliminary Injunction

NOTICE of Motion by James Edward Judge for presentment of motion for preliminary injunction 35 before Honorable John Robert Blakey on 7/16/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court denies without prejudice Plaintiff's renewed motion for preliminary injunction 35 because it remains incomplete; more specifically, the motion references an attached Exhibit but fails to attach the exhibit. Nor does the motion confirm notice to targeted Defendants, a prerequisite for relief under Fed. R. Civ. P. 65(a). The 7/16/25 Notice of Motion date is stricken. Mailed notice. (jn,)

NOTICE of Voluntary Dismissal by RC as to Certain Defandants

MOTION by Plaintiff RC for preliminary injunction Second Renewed Motion

(Ex. 1)

MEMORANDUM by RC in support of motion for preliminary injunction 39

NOTICE of Motion by James Edward Judge for presentment of motion for preliminary injunction 39 before Honorable John Robert Blakey on 7/23/2025 at 11:00 AM.

CERTIFICATE of Service by Plaintiff RC regarding memorandum in support of motion 40, MOTION by Plaintiff RC for preliminary injunction Second Renewed Motion 39

MINUTE entry before the Honorable John Robert Blakey: This case is dismissed with prejudice as to the following Defendants: Apalie-us (No. 67); NCCWAN (No. 68); Muxhel (No. 80); bigbigphoneseller (No. 84); and Myre_link2015 (No. 92). Additionally, Plaintiff shall ensure that all filings include Plaintiff's full name, Rinne Corp. Based upon its schedule, the Court strikes the 7/23/25 Notice of Motion date and sets this matter for hearing 7/30/25 at 11:00 a.m. in Courtroom 1203. Mailed notice.

NOTICE of Voluntary Dismissal by Rinne Corp. as to Certain Defandants

ATTORNEY Appearance for Defendant Topetitud by Michael M. Steinmetz

MOTION by Defendant Topetitud for extension of time to file response/reply as to amended complaint[10]

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the Notice of Voluntary dismissal, [44], this case is dismissed with prejudice under Rule 41(a) as to the following Defendants: Nokiils (No. 63); GT Life Power (No. 97); putianshuanUKaisho (No. 104); N-Market (No. 109); and HDN-168 (No. 110). Mailed notice.

NOTICE of Voluntary Dismissal by Rinne Corp. as to Certain Defendants

MOTION by Plaintiff Rinne Corp. for preliminary injunction Amended Second Renewed Motion

(Amended Ex. 1.)

MEMORANDUM by Rinne Corp. in support of motion for preliminary injunction 49

NOTICE of Motion by James Edward Judge for presentment of motion for preliminary injunction 49 before Honorable John Robert Blakey on 7/30/2025 at 11:00 AM.

CERTIFICATE of Service by Plaintiff Rinne Corp. regarding memorandum in support of motion 50, MOTION by Plaintiff Rinne Corp. for preliminary injunction Amended Second Renewed Motion 49

MINUTE entry before the Honorable John Robert Blakey: The Court denies as moot Plaintiff's second renewed motion for preliminary injunction [39] and grants Defendant Topetitud's motion to extend time [46]. All served Defendants shall respond to the complaint by 8/6/25. The case is dismissed with prejudice as to Defendants HLMOptimo SELECT (No. 77) and mlhpeak (No. 81). The case remains set for a hearing on Plaintiff's amended second renewed motion for entry of a preliminary injunction [49] on 7/30/25 at 11:00 a.m. in Courtroom 1203. Mailed notice.

MINUTE entry before the Honorable John Robert Blakey: The Court again denies Plaintiff's motion for preliminary injunction 49 because the proposed order accompanying the motion suggests that it remains directed against terminated parties (in particular, Shop1103835496 Store and MOJOYCE Speciality Store). The 7/30/25 Notice of Motion date is stricken. Mailed notice.

NOTICE of Voluntary Dismissal by Rinne Corp. as to Defendant LBDONDIN

MOTION by Plaintiff Rinne Corp. for preliminary injunction Third Renewed Motion

(Exhibit 1)

MEMORANDUM by Rinne Corp. in support of motion for preliminary injunction 56

NOTICE of Motion by James Edward Judge for presentment of motion for preliminary injunction 56 before Honorable John Robert Blakey on 8/6/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the notice of voluntary dismissal, 41, this case is dismissed with prejudice as to Defendants LBDONDIN (Def. No. 65), HLMOptimo SELECT (Def. No. 77), mlhpeak (Def. No. 80) under Rule 41(a). Mailed notice.

MOTION by Defendant Topetitud to dismiss for lack of jurisdiction

Exhibit Declaration in support of MTD

Exhibit Sunbiz

(Exhibit Amazon account)

MINUTE entry before the Honorable John Robert Blakey: Plaintiff shall respond to the motion to dismiss filed by Defendant Topetitud (No. 70) 60 by 8/18/25, and Defendant Topetitud shall file any reply by 8/25/15. The Court takes under advisement Plaintiff's motion for preliminary injunction 56 and strikes the 8/6/25 Notice of Motion date; the Court will consider the motion once it resolves the jurisdictional challenges raised in the motion to dismiss. Mailed notice.

RESPONSE by Rinne Corp. in Opposition to MOTION by Defendant Topetitud to dismiss for lack of jurisdiction 60

Declaration of Ying Chen

Ex.1

(Ex.2)

NOTICE of Voluntary Dismissal by Rinne Corp. as to Defendant Duratoolstore-US

REPLY by Topetitud to response in opposition to motion[62]

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the notice of voluntary dismissal, 63, this case is dismissed with prejudice as to Defendant Duratoolstore-US (Def. No. 40) under Rule 41(a). Mailed notice.

NOTICE of Voluntary Dismissal by Rinne Corp. as to Defendant Juyuanya

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the notice of voluntary dismissal, 66, this case is dismissed with prejudice as to Defendant Juyuanya (Def. No. 76) under Rule 41(a). Mailed notice.

NOTICE of Voluntary Dismissal by Rinne Corp. as to Certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the notice of voluntary dismissal, 68, this case is dismissed with prejudice as to Defendant ying ka (75) under Rule 41(a). Mailed notice.