2025-cv-07270

COMPLAINT for Copyright Infringement filed by Hong Kong Leyuzhen Technology Co. Limited; Jury Demand. Filing fee $ 405, receipt number AILNDC-23684772.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

Declaration of Katherine M. Kuhn in Support of Motion for Leave to File Under Se

(Exhibit 2 to the Declaration of K. Kuhn)

Exhibit 1 to the Supplement

Exhibit Memorandum in Support of Motion for Electronic Service

Exhibit Memorandum in Support of Motion for Temporary Restraining Order

Exhibit 1 to the Complaint

Exhibit Memorandum in Support of Renewed Motion for Temporary Restraining Order

Exhibit Memorandum in Support of Motion for Preliminary Injunction

Exhibit Memorandum in Support of Motion for Default and Default Judgment

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Complaint regarding complaint, [1]

Exhibit 2 to the Complaint

(Exhibit 6 to the Complaint)

Exhibit 1 to the Declaration of K. Kuhn

Declaration of Katherine M. Kuhn in Support of Motion for Electronic Service

Declaration of Katherine M. Kuhn in Support of Motion for Temporary Restraining

Exhibit 2 to the Complaint

Declaration of Katherine M. Kuhn in Support of Renewed Motion for Temporary Rest

Declaration of Joseph W. Droter in Support of Motion for Preliminary Injunction

Declaration of Katherine M. Kuhn in Support of Motion for Default and Default Ju

CIVIL Cover Sheet

Exhibit 3 to the Complaint

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 3 to the Complaint

Exhibit 1 to the Declaration of K. Kuhn

Exhibit 1 to the Declaration of J. Droter

Exhibit 1 to the Declaration of K. Kuhn

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal

Exhibit 4 to the Complaint

Exhibit 2 to the Declaration of K. Kuhn

Exhibit 4 to the Complaint

Exhibit 2 to the Declaration of K. Kuhn

Declaration of Liangjie Li in Support of Motion for Default and Default Judgment

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to seal [4]

Exhibit 5 to the Complaint

Exhibit 3 to the Declaration of K. Kuhn

Exhibit 5 to the Complaint

Exhibit 3 to the Declaration of K. Kuhn

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Hong Kong Leyuzhen Technology Co. Limited

Exhibit 6 to the Complaint

Exhibit 4 to the Declaration of K. Kuhn

Exhibit 6 to the Complaint

Exhibit 4 to the Declaration of K. Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Katherine Marilyn Kuhn

Exhibit 5 to the Declaration of K. Kuhn

Exhibit 5 to the Declaration of K. Kuhn

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Joseph Wendell Droter

Declaration of Liangjie Li in Support of Motion for Temporary Restraining Order

Declaration of Liangjie Li in Support of Renewed Motion for Temporary Restrainin

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff Hong Kong Leyuzhen Technology Co. Limited by Gokalp Bayramoglu

CASE ASSIGNED to the Honorable John J. Tharp, Jr. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 3). (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: Shenzhen Anxin Home Textiles Co., Ltd., Guangzhou Ziya Network Technology Co., Ltd., Guangdong Yihang Foreign Trade Clothing Co., Ltd., Guangzhou Linlin Garment Co., Ltd., Guangzhou Umay Clothing Co., Ltd. and Dalian Xingxing International Trade Co., Ltd. added to case caption. (Text entry; no document attached.)

MAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable John J. Tharp, Jr:The motion to seal [4] is granted. By 7/7/25, the plaintiff is required to file (1) a listing of all prior online trademark, copyright, or patent infringement cases (also known as "Schedule A" cases) filed in any court in the United States in which it was a plaintiff, and (2) a listing of any of the defendants included in the Schedule A in this case that the plaintiff has previously named as a defendant in any prior complaint or Schedule A case. Mailed notice

SUPPLEMENT to order on motion to seal, terminate motions, [12] in Compliance with Docket 12

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Supplement regarding supplement[13]

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motions for electronic service and a temporary restraining order [15] [16] are taken under advisement. By 7/24/25, the plaintiff is required to supplement its motion with a certification that the plaintiff has not used any of the screenshot evidence supplied in support of its motion in any prior proceeding. Upon review of the index of screenshots [16-7], the screenshots do not show a single copyright that was allegedly infringed by each of the defendants listed in the plaintiff's Schedule A, raising a question as to the propriety of joinder. Plaintiff is directed, by 7/24/25, to supplement the TRO motion with a brief explaining why joinder is proper notwithstanding the lack of a single copyright common to all defendants. (In other words, the brief should explain why joinder of claims of infringement of different copyrights is appropriate in this case.) If the brief contains new screenshots, those screenshots must be included in an updated version of the certification and index attached to Plaintiff's TRO motion. Alternatively, the plaintiff may amend its complaint to include only defendants alleged to have violated the same copyright and file a renewed motion for entry of a TRO. Mailed notice

FIRST AMENDED complaint by Hong Kong Leyuzhen Technology Co. Limited against The Partnerships and Unincorporated Associations identified in Schedule A for Copyright Infringement

SEALED EXHIBIT by Plaintiff Hong Kong Leyuzhen Technology Co. Limited Exhibit 1 to the Complaint regarding amended complaint, [18]

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order and Expedited Discovery RENEWED

SUPPLEMENT to order on motion for service by publication, order on motion for temporary restraining order, set motion and R&R deadlines/hearings, [17] Certification of Evidence in Compliance with Docket 17

MINUTE entry before the Honorable John J. Tharp, Jr:On the grounds set forth in the motion, plaintiff's renewed ex parte motion for TRO and expedited discovery [20] is granted. Enter temporary restraining order. Mailed notice

SEALED Temporary Restraining Order Signed by the Honorable John J. Tharp, Jr on 7/21/2025. Mailed notice

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified in Schedule A by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

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

SURETY BOND in the amount of $ 6,000 posted by Hong Kong Leyuzhen Technology Co. Limited. (Document not scanned).

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to The Partnerships and Unincorporated Associations identified in Schedule A on 7/31/2025, answer due 8/21/2025.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of a preliminary injunction [28] is taken under advisement. Any objection or response is due before 8/5/25. Upon review of the certificate of service, the Court directs the plaintiff, by 8/4/25, to publish the preliminary injunction motion to its website along with prominent text advising defendants that (1) a motion for entry of a preliminary injunction has been filed, and (2) any responses or objections to that motion must be filed before 8/5/25. The plaintiff must also provide to each defendant the screenshot evidence relevant to that defendant (that is, screenshot evidence showing the allegedly infringing product or products sold by the defendant) offered in support of the temporary restraining order. Mailed notice

CERTIFICATE of Service in Compliance with Docket 29 by Joseph Wendell Droter on behalf of Hong Kong Leyuzhen Technology Co. Limited regarding order on motion for preliminary injunction, set motion and R&R deadlines/hearings, [29]

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, plaintiff's motion for entry of a preliminary injunction [28] is granted. Enter preliminary injunction order. The preliminary injunction directs, among other things, that Schedule A be unsealed. Plaintiff is ordered to enter in CM/ECF no later than 8/7/25 each defendant named in the original Schedule A as a party in this case (where a defendant has been dismissed, the CM/ECF entry should reflect that status). Failure to timely comply with this requirement may result in vacating the preliminary injunction. For instructions as to how to add parties to the case docket, see https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Mailed notice.

PRELIMINARY INJUNCTION Order Signed by the Honorable John J. Tharp, Jr on 8/5/2025. Mailed notice.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for default judgment as to 6 Defaulting Defendants

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment [33] is taken under advisement. Any objections or responses are due by 9/2/25. The plaintiff is directed to provide defendants with notice of the default proceedings against them by 8/26/25. To effectuate that notice, the Court directs the plaintiff to (1) update the website through which it has been publishing information about the case to provide notice of its motion for entry of default and default judgment, as well as the deadline to object set forth in this order, and (2) send an email to the email addresses provided for the defendants by third parties (or otherwise obtained by the plaintiff) informing them of the default proceedings against them, attaching a copy of plaintiff's motion for default judgment, memorandum in support thereof, and this order, and containing a link to the updated website. Mailed notice

CERTIFICATE of Service in Compliance with Docket 34 by Joseph Wendell Droter on behalf of Hong Kong Leyuzhen Technology Co. Limited regarding order on motion for default judgment, set motion and R&R deadlines/hearings, [34]

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment [33] is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 9/4/2025. Mailed notice