2025-cv-06464

COMPLAINT filed by Shenzhen Jiyou Supply Chain Co. LTD. ; Filing fee $ 405, receipt number AILNDC-23606360.

Exhibit Schedule A

(Exhibit)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Shenzhen Jiyou Supply Chain Co. LTD. by Longhao Wang

NOTICE by Shenzhen Jiyou Supply Chain Co. LTD. of claims involving patents

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Jiyou Supply Chain Co. LTD.

CASE ASSIGNED to the Honorable Georgia N Alexakis. Designated as Magistrate Judge the Honorable Keri L. Holleb Hotaling. 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.

MINUTE entry before the Honorable Georgia N Alexakis: Upon review of the complaint, the Court sua sponte raises the propriety of joining 45 defendants in a single action. By 6/26/25, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of this Court's orders in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagram International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). In the alternative, plaintiff has leave to file an amended complaint by 6/26/25 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting this Court's order in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025).

MAILED Patent report to Patent Trademark Office, Alexandria VA

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 8/18/25 at 9:30 a.m. in person in Courtroom 1719. By 8/11/25, the parties shall file a Joint Initial Status Report that complies with the Court's standing order, which can be found on the Court's website. If the defendant(s) have not been served by the initial status hearing date, counsel for Plaintiff must contact the Courtroom Deputy to reschedule the status hearing and the date for filing the Joint Initial Status Report.

AMENDED complaint by Shenzhen Jiyou Supply Chain Co. LTD. against The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A

Exhibit Schedule A

Exhibit Exhibit A

Exhibit Exhibit B (part 1)

Exhibit Exhibit B (part 2)

Exhibit Exhibit B (part 3)

(Exhibit Exhibit B (part 4))

MEMORANDUM by Shenzhen Jiyou Supply Chain Co. LTD. establishing that joinder is proper

Exhibit A

(Exhibit B)

MINUTE entry before the Honorable Georgia N Alexakis: The Court has reviewed plaintiff's memorandum regarding joinder [1o] and determines that plaintiff has failed to satisfy its burden to show that joinder of 45 defendants is proper under Federal Rule of Civil Procedure 20. See Estee Lauder Cosms. Ltd. v. The Partnerships, 334 F.R.D. 182, 185 (N.D. Ill. 2020) ("[plaintiff] bears the burden of demonstrating that joinder is proper"). In so concluding, the Court adopts its analyses in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagram International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). According to plaintiff, joinder of 45 defendants is proper because a small subset of the 45 defendants use identical product photos, identical product names, identical product descriptions, and nondescript names or aliases. 10 at 4. From there, plaintiff argues that the defendants likely coordinate amongst themselves. Id. This rationale for joinder is one that the Court already addressed, and rejected, in Anagram International and Bug Art Limited. See also Toyota Motor Sales, USA, Inc. v. The Partnerships, 24 CV 9401, Dkt. 27 at 23 (N.D. Ill. Nov. 18, 2024) ("Even if the t-shirts came from the same factory, and even if the unauthorized vendors employed the same hustle, I would have a hard time establishing a connection between a vendor in Chicago and a vendor in Los Angeles, even though they fit a particular profile."); Estee Lauder, 334 F.R.D. at 188 ("Considering that the Defendants are copying the Este Lauder products, it is not a surprise that the counterfeited end-results, along with their images and descriptions, would be similar."). Plaintiff is ordered to show cause in writing by 7/11/25 why this case should not be dismissed. Plaintiff's response to the Court's show cause order must also address why, when filing the instant case, plaintiff did not seek to have this case assigned to District Judge Pacold, consistent with NDIL Local Rule 40.3(b), where plaintiff concedes this case and a previous case before Judge Pacold (which plaintiff voluntarily dismissed after Judge Pacold denied plaintiff's motion for a temporary asset restraint) involved the same plaintiff, the same patent, and "a subset" of the same defendants. See 10 at 8; L.R. 40.3(b) ("When a case is dismissed with prejudice or without, and a second case is filed involving the same parties and relating to the same subject matter, the second case shall be assigned to the judge to whom the first case was assigned. The designation sheet presented at the time the second case is filed shall indicate the number of the earlier case and the name of the judge to whom it was assigned.").

NOTICE of Voluntary Dismissal by Shenzhen Jiyou Supply Chain Co. LTD.

NOTICE of Voluntary Dismissal by Shenzhen Jiyou Supply Chain Co. LTD.

RESPONSE by Plaintiff Shenzhen Jiyou Supply Chain Co. LTD. to text entry, 11 rule to show cause

Exhibit A

Exhibit B

(Exhibit C)

MINUTE entry before the Honorable Georgia N Alexakis: Plaintiff's memorandum in response to the rule to show cause 14 is sufficient to discharge the Court's rule to show cause. Rule discharged.

MINUTE entry before the Executive Committee: It appearing that, due to a clerical error case 25-cv-06464, Shenzhen Jiyou Supply Chain Co. LTD. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, And Unincorporated Associations Identified On Schedule A, was assigned in error to the Honorable Georgia N Alexakis, therefore IT IS HEREBY ORDERED that the assignment of 25-cv-06464, to the Honorable Georgia N Alexakis, be vacated as the assigned judge and the case shall be reassigned directly to the Honorable Martha M. Pacold who was assigned the previously dismissed matter, 24-cv Mailed notice

(Request for Reassignment)

MINUTE entry before the Honorable Georgia N. Alexakis: Given the reassignment of this matter to Judge Pacold 16, Judge Alexakis vacates the 8/18/25 initial status hearing.

Second AMENDED complaint by Shenzhen Jiyou Supply Chain Co. LTD. against Dongguan Huangjiang Jinliangtang Hardware Factory

Exhibit A

Exhibit B