2025-cv-06173

COMPLAINT filed by Collegiate Licensing Company, LLC; Filing fee $ 405, receipt number AILNDC-23571732.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Schedule A regarding complaint[1]

MOTION by Plaintiff Collegiate Licensing Company, LLC for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Collegiate Licensing Company, LLC

Notice of Claims Involving Trademarks by Collegiate Licensing Company, LLC

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Allyson M. Martin

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Rachel S Miller

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

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.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 2).

NEW PARTIES: Shenzhen Starship Troopers, Traulle, WANSHENUS, weiyou-US, XHGROUP, Xiaopengstore, XIAOXIBAI, XieYuLing665, xushu-US, YAO-TX, Yebizan, yingfeng-US, yingpeiw, yuyun-US, zhouzhao shop, sport boy, taa-6551, toland_harwick, tubeh0, vnrgdwse, wanghaoxi, weiping-5, wenganceng, wenzuo-3, wqwk4083, wwangshaobin, xiakoman77, xiangdi60, xiaochengjiashangmao, xuanxue-2, xunn-14, yangjiangshirongranxu0, yao21575687, yiwushiruiqiangm0, yuezi2, yugang-1, yunzed0, zhichen2, zhichen2-9, zhijiangshiduangais_0, zhipe_77, zhuzhoushichengban0, zona_gsrant, Super Mens Fashion local, Superinrin, SYKGSCYGYC, T shirt Personalized Customization, TchicWear, TeeGenius, The Beauty of Women, The early bird catches the worm, This is nicing, Three D Printing Dream, thuth, TIMISTYLE, TMxiuaitwo, TONEWAWA, TPGRG, TREND SPHERE, Trendy Closets, Trendy Hoodie Terrace, TRENDY U, TTPALACE, TTTSP, Tuesday Treasures, umi buff, Urban Muse, UrbansVogue, UrbanVanguard, USLine, USLIVE, usqianhe, Vitality Youth Studio, voerburon shop, Voguish Verse, VT Club, WANSON APPAREL, WarmSun YF, Wednesday Wardrobe, WENDI LIFE, wenghuoqing, Wincup, WINTEMUR, WJGFLKGdd, WsTshirt, WUWEIJIAC, X Art, XF casual mens wer, xiaohuanche, xiaotuC, xichengfa, xilixili, Xiubei Rabbit Four, xxshaocongxx, Y Y Fashion, YaYwaiYaY, ybytwo, YelRelCoo, Yeye infinite progress, YGUSTD, Yichi studio, yinmotou, YOUMIHUA, Your Choi, YYGYKI, ZENDXI, ZGUANNIAN, ZHIHERHAO, ZKISEROH, Zoofashion, ZSP Fashion, Pengchengming, QZWL STORE, Shichuan, SZCL-MART, XiYue Clo, yanruxiaobaodeaixindianpu, yixinmaoyi, YuYuanClothing, Z-Gen Glam and ZhiQiang Zhang added to case caption.

ENTERED IN ERROR Modified on 6/4/2025.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Mailed notice.

MOTION by Plaintiff Collegiate Licensing Company, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for temporary restraining order[15]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[16]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Lindsay Conn regarding memorandum in support of motion[16]

SEALED EXHIBIT by Plaintiff Collegiate Licensing Company, LLC Exhibit 1 - Parts 1-2 regarding declaration[18]

DECLARATION of Sterling Hawkins regarding memorandum in support of motion[16]

Exhibit 1

MOTION by Plaintiff Collegiate Licensing Company, LLC for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for miscellaneous relief[21]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[22]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [15] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [21] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 6/6/2025. Mailed notice.

Registry Deposit Information Form by Collegiate Licensing Company, LLC

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Collegiate Licensing Company, LLC

SUMMONS Issued (Court Participant) as to 2024 FAST Clearance SALE and all other Defendants identified in the Complaint

SURETY BOND in the amount of $ 9,000.00 posted by Collegiate Licensing Company, LLC

MOTION by Plaintiff Collegiate Licensing Company, LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Collegiate Licensing Company, LLC in support of extension of time[30]

Declaration of Allyson M. Martin

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order [30] is granted. The Temporary Restraining Order entered on 6/6/2025 [26] is extended by a period of fourteen (14) days until 7/7/2025. Mailed notice.

MOTION by Plaintiff Collegiate Licensing Company, LLC for preliminary injunction

Exhibit A

MEMORANDUM by Collegiate Licensing Company, LLC in support of motion for preliminary injunction[34]

Declaration of Allyson M. Martin

SUMMONS Returned Executed by Collegiate Licensing Company, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 6/30/2025, answer due 7/21/2025.

Declaration of Rachel S. Miller

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 34 is set for 7/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Marcella Deshonda Slay

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 7/7/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 34 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibits to the Declaration of Lindsay Conn 19, and the TRO 26. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 8/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 7/7/2025. Mailed notice.

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Trevor Christian Talhami

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 8/7/2025. A telephone status hearing is set for 9/12/2025 at 9:30 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

ATTORNEY Appearance for Defendant Urban Muse by Xuanjie Wang

MOTION by Defendant Urban Muse for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable Thomas M. Durkin: The court adopts the following agreed briefing schedule as to Defendant's first motion to extend deadline to answer or otherwise respond to the complaint [44]: Plaintiff is to respond by 9/12/2025; Defendant is to reply by 9/17/2025. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/12/2025 is reset for 9/24/2025 at 9:00 a.m. Mailed notice.

RESPONSE by Plaintiff Collegiate Licensing Company, LLC to motion for extension of time to file answer 44

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/24/2025 at 9:00 a.m. is reset for 9:15 a.m. Time change only. Mailed notice.

REPLY by Urban Muse to Response 47

(Exhibit A)

ATTORNEY Appearance for Defendant Urban Muse by Christopher James Fahy

MINUTE entry before the Honorable Thomas M. Durkin: Telephone status hearing held on 9/24/2025. Defendant Urban Muse's first motion to extend the deadline to answer or otherwise respond to the complaint [44] is granted. Defendant's answer is due by 10/7/2025. A telephone status hearing is set for 11/3/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. 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.

ATTORNEY Appearance for Plaintiff Collegiate Licensing Company, LLC by Kahlia Roe Halpern