2025-cv-06652

COMPLAINT filed by Dreams USA Inc.; Filing fee $ 405, receipt number AILNDC-23632748.

Exhibit Exhibit 1

Declaration Declaration of Plaintiff

Declaration Declaration of David Gulbransen

SEALED DOCUMENT by Plaintiff Dreams USA Inc. Schedule A to Complaint

Exhibit Exhibit 2

Declaration Declaration of David Gulbransen

Exhibit Exhibit 1

CIVIL Cover Sheet

Exhibit Exhibit 2 to Declaration of David Gulbransen

USPTO Cover Sheet by Dreams USA Inc.

Affiliate Disclosure by Dreams USA Inc.

ATTORNEY Appearance for Plaintiff Dreams USA Inc. by David Lee Gulbransen, Jr

MOTION by Plaintiff Dreams USA Inc. to seal document sealed document[2]

CASE ASSIGNED to the Honorable Sunil R. Harjani. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 2). (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.)

NEW PARTIES: Zhongshan Aumeter Technology Co., Ltd. added to case caption. (Text entry; no document attached.)

MAILED copyright report to Registrar, Washington DC

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff shall file a status report with an update on the case by 7/9/2025. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff did not file the status report due by 7/9/2025. Plaintiff is directed to file a status report with an update on the case by 7/16/2025. Mailed notice

SEALED DOCUMENT by Plaintiff Dreams USA, Inc. Revised Schedule A

MOTION by Plaintiff Dreams USA, Inc. for temporary restraining order

AFFIDAVIT by Plaintiff Dreams USA, Inc. in Support of MOTION by Plaintiff Dreams USA, Inc. for temporary restraining order [14]

SEALED DOCUMENT by Plaintiff Dreams USA, Inc. Exhibit 1 to Delcaration of David Gulbransen

MOTION by Plaintiff Dreams USA, Inc. for leave to file excess pages

MOTION by Plaintiff Dreams USA, Inc. to seal document sealed document[16]

STATUS Report by Dreams USA, Inc.

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motions for leave to file under seal [7] [18], ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and motion for electronic service of process [14], and motion for leave to file excess pages [17] are granted. Plaintiff's submissions establish that were defendant to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendant could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motions to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendant to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that its assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendant, stopping defendant's infringing conduct, and obtaining an accounting. Further, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), 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 products, and there is no countervailing harm to defendant from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to defendant. Expedited discovery is warranted to identify defendant and to implement the asset freeze. Enter Sealed Temporary Restraining Order at 2:00 p.m. on 7/17/2025. Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) if appropriate no later than 7/24/2025. Telephone status hearing is set for 7/31/2025 at 9:15 a.m. Mailed notice

SEALED EX PARTE TEMPORARY RESTRAINING ORDER WITH ASSET FREEZE AND OTHER EQUITABLE RELIEF Signed by the Honorable Sunil R. Harjani on 7/17/2025. Mailed notice

MOTION by Plaintiff Dreams USA, Inc. for extension of time of TRO

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order [22] is granted. For the reasons stated in Plaintiff's Memorandum [22], the Court finds good cause to extend the temporary restraining order an additional 14 days to 8/14/2025. Plaintiff shall file a preliminary injunction motion if appropriate no later than 8/7/2025. Telephone status hearing set for 7/31/2025 is stricken and reset to 8/14/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) Zhongshan Aumeter Technology Co., Ltd. and all other Defendants identified in the Complaint by Plaintiff Dreams USA, Inc.

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

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff is directed to file a status report with an update on the case by 8/14/2025. Telephone status hearing set for 8/14/2025 is stricken and reset to 8/21/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MOTION by Plaintiff Dreams USA, Inc. for preliminary injunction

MEMORANDUM by Dreams USA, Inc. in support of motion for preliminary injunction[27]

SUMMONS Returned Executed by Dreams USA, Inc. as to Partnerships and Unincorporated Associations Identified on Schedule A on 8/8/2025, answer due 8/29/2025.

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion [27] for entry of a preliminary injunction. In connection with that motion, plaintiff must serve the defendant 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 8/18/2025." 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 8/18/2025. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing. Plaintiff must serve this minute order upon the defendant within one business day of its entry on the docket and must promptly file proof of that service. Status hearing set for 8/21/2025 at 9:15 a.m. is converted to a tentative preliminary injunction hearing. Mailed notice

CERTIFICATE of Service by Plaintiff Dreams USA, Inc. regarding terminate hearings, set/reset hearings, [30]

STATUS Report by Dreams USA, Inc.

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff shall post the bond as required in the Temporary Restraining Order [21] by 8/20/2025. Tentative preliminary injunction hearing set for 8/21/2025 is stricken. Mailed notice

MOTION by Plaintiff Dreams USA, Inc. for extension of time to file surety bond

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for extension of time to file surety bond [34] is granted. Mailed notice

SURETY BOND in the amount of $ 10,000 posted by Dreams USA, Inc.

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for a preliminary injunction [27] is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court finds that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds 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 [31] that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk is requested to unseal any previously-sealed documents: Schedule A [2], Revised Schedule A [13]; Exhibit 1 to Declaration of David Gulbransen [16]; and the TRO [21]. Summons was issued on 8/8/2025, and Defendants' responses to the complaint are due by 8/29/2025. Plaintiff should file any motion for entry of default and default judgment by 9/16/2025. If there are any remaining defendants whom default and default judgment are not being sought, Plaintiff is ordered to file a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. A telephone status hearing is set for 10/14/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Sunil R. Harjani on 8/22/2025. Mailed notice