2025-cv-06583

COMPLAINT filed by Converse Inc.; Filing fee $ 405, receipt number AILNDC-23621588.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Berel Y. Lakovitsky

(Exhibit A)

Exhibit A

(Exhibit A)

Exhibit 1

(Exhibit 1)

Exhibit A

SEALED EXHIBIT by Plaintiff Converse Inc. Schedule A regarding complaint[1]

Exhibit A

(Exhibit B)

(Exhibit 2)

MOTION by Plaintiff Converse Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Converse Inc.

Notice of Claims Involving Trademarks by Converse Inc.

ATTORNEY Appearance for Plaintiff Converse Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Converse Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Converse Inc. by Marcella Deshonda Slay

ATTORNEY Appearance for Plaintiff Converse Inc. by Berel Yonathan Lakovitsky

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.)

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Civil Category Two). (Text entry; no document attached.)

NEW PARTIES: Ares, CHANGYANMAOYI, ChaoFangG, ChuangYangDengShi, chunjukuajingdianpu, GhYI, Honouredbird, Hyamass Direct, LvJuN, Martinez pet, PODEQeeStore, qiwa, UniKorNa, wanghongmei123., YIKEYANG SHOP, YingChengBaiHuo, yinuo111, YIQIANDANSHANGMAO, yunchengyifengshangmaoyouxiangongsi, Zhan Bin, breadqiao2010, donghaistone, eastjewellery, luoerdasan-0, meliespresso, qyxcrystal, qyxzhubao, Sweet Kitty Couture, pweesdf and tshadow3 added to case caption. (Text entry; no document attached.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Lindsay C. Jenkins: The Court grants the motion to seal [3]. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting the opinion issued in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025) (Alexakis, J.). Mailed notice.

MOTION by Plaintiff Converse Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Converse Inc. in support of motion for temporary restraining order[14]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

DECLARATION of Joe Pallett regarding memorandum in support of motion[15]

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 2 regarding declaration[17]

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

MEMORANDUM by Converse Inc. in support of motion for miscellaneous relief[19]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

SEALED DOCUMENT by Plaintiff Converse Inc. Schedule A Template

MINUTE entry before the Honorable Lindsay C. Jenkins: The ex parte motion for a temporary restraining order is granted [14] such that the asset restraint may apply only to money or assets traceable to sales of the accused products. Were Defendants to learn of these proceedings before the execution of Plaintiff's requested preliminary injunctive relief, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. The Temporary Restraining Order being entered along with this minute order shall be placed under seal. In addition, for the purpose of the motions cited above, Plaintiff's filings support proceeding (for the time being) on an ex parte basis. Specifically, were defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating Plaintiff's interests in identifying defendants, stopping Defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by Plaintiff shows a likelihood of success on the merits, that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. Enter Sealed Temporary Restraining Order. The motion for electronic service [19] is also granted. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Lindsay C. Jenkins on 6/20/2025. Mailed notice.

Registry Deposit Information Form by Converse Inc.

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff Converse Inc.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ 10,000.00 posted by Converse Inc.

MOTION by Plaintiff Converse Inc. for preliminary injunction

MEMORANDUM by Converse Inc. in support of motion for preliminary injunction[29]

DECLARATION of Marcella D. Slay regarding memorandum in support of motion[30]

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

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all remaining 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 July 3, 2025." 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 Converse Inc. regarding text entry, 33

ATTORNEY Appearance for Defendant Municipal by Benjamin Adam Campbell

MOTION by Defendant Municipal to stay Discovery and Modify Asset Restraint, Notice of Opposition, and Request for Briefing Schedule

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's response to the motion to modify by Defendant Municipal 36 is due by July 14, 2025 and any reply is due by July 21, 2025. While the court reserves a final decision until the motion is fully briefed, Defendant Municipal alleges that Plaintiff was able to freeze all of the assets in Municipal's account with Amazon, which is approximately $18,851.26. The court's temporary restraining order applied only to money or assets traceable to sales of the accused products, so if third-party platforms restrained funds that are not traceable to infringement, plaintiff may be liable to defendant for damages from a wrongful injunction. The court encourages the parties to confer to the extent that they can reach a resolution without further court action. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendant Municipal. Plaintiff's motion for a preliminary injunction 36 is granted, which the Court now considers unopposed because no defendant filed a notice of objection by the established deadline. For the reasons set forth in plaintiff's motion for a preliminary injunction, as well as the reasons provided by plaintiff in connection with the Court's earlier entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction, including 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 34 that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents. Enter preliminary injunction order. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable Lindsay C. Jenkins on 7/7/2025. Mailed notice.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to those Defendant Municipal. By July 28, 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.

MOTION by Plaintiff Converse Inc. to Stay Deadlines and Notice of Settlement (Joint)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion to stay 42 is granted. The briefing schedule as to Defendant Municipal is stricken and a stipulation of dismissal is due by August 14, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MINUTE entry before the Honorable Lindsay C. Jenkins: In light of the voluntary dismissal against the last remaining Defendant 44 there is no work for the court left to do. Civil case terminated. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Dkt. 46, having been entered in error, is vacated. Mailed notice.

MOTION by Plaintiff Converse Inc. for entry of default, MOTION by Plaintiff Converse Inc. for default judgment as to all Defendants with the exception of a certain Defendant

MEMORANDUM by Converse Inc. in support of motion for entry of default, motion for default judgment, 48

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 49

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 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 August 4, 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 July 31, 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 Converse Inc. regarding order on motion for entry of default, order on motion for default judgment, text entry, [51]

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

ATTORNEY Appearance for Defendant Ares by Adam Edward Urbanczyk

MOTION by Defendant Ares for extension of time

MINUTE entry before the Honorable Lindsay C. Jenkins: The following order does not apply to Defendant Ares. No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion [48] 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. Enter Final Judgment Order. Mailed notice.

ENTERED JUDGMENT as to certain defendants Signed by the Honorable Lindsay C. Jenkins on 8/5/2025. Mailed notice.

MINUTE entry before the Honorable Lindsay C. Jenkins: Defendant Ares' motion for an extension of time [55] is granted. Defendant Ares' responsive pleading is now due by August 25, 2025. Mailed notice.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendant

MINUTE entry before the Honorable Lindsay C. Jenkins: A stipulation of dismissal [59] has been filed as to the last Defendant, Ares. There is no remaining work for the court, so the case can be closed. Civil case terminated. Mailed notice.