2025-cv-07374

COMPLAINT filed by United Beauty Brands, LLC ; Filing fee $ 405, receipt number AILNDC-23693904.

Exhibit 1

Declaration of Martin F. Trainor

Exhibit 1

Declaration of Martin F. Trainor

Exhibit 1

SEALED EXHIBIT by Plaintiff United Beauty Brands, LLC Schedule A regarding complaint, [1]

Exhibit 2

Exhibit 8

Exhibit 2

Exhibit 1

MOTION by Plaintiff United Beauty Brands, LLC for Leave to File Certain Documents Under Seal

Exhibit 3

Exhibit 3

CIVIL Cover Sheet

Exhibit 4

Exhibit 4

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by United Beauty Brands, LLC

Exhibit 5

Exhibit 5

Notice of Claims Involving Trademarks by United Beauty Brands, LLC

Exhibit 6

Exhibit 6

ATTORNEY Appearance for Plaintiff United Beauty Brands, LLC by Martin Francis Trainor

Exhibit 7

Exhibit 7

ATTORNEY Appearance for Plaintiff United Beauty Brands, LLC by Alexander Whang

Exhibit 8

Exhibit 8

ATTORNEY Appearance for Plaintiff United Beauty Brands, LLC by Sydney Paige Fenton

Exhibit 9

Exhibit 9

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. 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: Guangzhou Meidishi Biotechnology Co., Ltd added to case caption. Terminating The Partnerships And Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. Plaintiff names 51 Defendants in this single case [2]. However, after reviewing the complaint [1] and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all Defendants. See Fed. R. Civ. P. 20(a)(2); Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). In addition, because Plaintiff filed a form complaint with generic allegations about "Defendants" allegedly violating federal trademark laws without any details whatsoever about the defendants identified in Schedule A, the Court doubts that the complaint satisfies the requirements of with Federal Rules of Civil Procedure 8 and 10. Accordingly, by 7/24/25, Plaintiff must either (a) file an amended complaint and an amended Schedule A under seal with a subset of Defendants, and the amended complaint must set forth with specific allegations about each defendant identified in Plaintiff's amended Schedule A, including allegations that explain how each defendant is properly joined with each other and labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only; or (b) file a supplemental memorandum that refers to specific facts alleged in its filings and provides citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper and the allegations are sufficient under Rules 8 and 10. Otherwise, this case will be dismissed. Finally, Plaintiff's motion to seal [3] was not noticed for presentment in accordance with this Court's case management procedures. Counsel is reminded to review and comply with all court procedures. For future reference, non-compliant motions may be summarily stricken. Counsel is admonished to review and comply with all court procedures and applicable rules. The motion to seal [3] is taken under advisement until the joinder issue is resolved. Mailed notice.

Exhibit 10

Exhibit 10

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

Exhibit 11

Exhibit 11

MEMORANDUM by United Beauty Brands, LLC Establishing that Joinder is Proper

SEALED EXHIBIT by Plaintiff United Beauty Brands, LLC Exhibit 1, Parts 1-5 regarding memorandum[12]

SEALED EXHIBIT by Plaintiff United Beauty Brands, LLC Exhibits 2-7 regarding memorandum[12]

MOTION by Plaintiff United Beauty Brands, LLC for Leave to File Certain Documents Under Seal

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[15] before Honorable LaShonda A. Hunt on 7/29/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: In response to the Court's order [10] questioning whether Plaintiff had met its burden of establishing that permissive joinder of 51 Defendants in this case was proper under Fed. R. Civ. P. 20(a)(2), Plaintiff filed a memorandum [12] and provisionally sealed exhibits [13] [14] showing the allegedly infringing products as well as "batch codes" that Plaintiff claims establishes these "Defendants are related in some manner." (Dkt. 12, at 438). As this Court has repeatedly explained, that is merely a conclusory allegation that all defendants' actions arise out of the same transaction, occurrence, or series of transactions or occurrences. See Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule A, No. 24 C 1566, 2024 WL 2953105, at *3 (N.D. Ill. June 6, 2024) (finding that plaintiff had merely identified a "small subset of the 181 defendants who are copycats of Plaintiff's style and each other, but that does not make them all partners in collusion) (emphasis in original); Bailie, et al. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, No. 24 C 2150, 2024 WL 2209698, at *5 (N.D. Ill. May 15, 2024) (finding use of same images and similar product titles and descriptions insufficient to support joinder); Ilustrata Servicos Design, Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule A, No. 21 C 5993, 2021 WL 5396690, at * 2 (Nov. 18, 2021) (holding that plaintiff's speculation that defendants were interrelated because they shared notable features "including use of the user name registration patterns, unique shopping cart platforms, accepted payment methods, check-out methods, meta data, illegitimate SEO tactics, HTML user-defined variables, lack of contact information, identically or similarly priced items and volume sales discounts, similar hosting services, similar name servers, and the use of the same text and images" did not support joinder). Plaintiffs in these trademark infringement cases must follow the same rules as any other civil litigant appearing before this Court. Because Plaintiff has failed to cure the misjoinder here, the Court exercises its discretion to do so. Defendants 2-51 are dismissed without prejudice for improper joinder. This action will proceed as to Defendant 1 only. Finally, Plaintiff's motions for leave to file under seal [3] [15] are denied. There are no grounds for continued sealing of this case, as Plaintiff has not sought injunctive relief. The clerk's office is directed to unseal Schedule A [2], Exhibits 1 [13] and 2-7 [14] to the Declaration of Martin F. Trainor [12]. The motion hearing set for 7/29/25 [16] is stricken. If no other relief has been sought, Plaintiff is ordered to file a status report by 8/15/25 updating the Court on proposed next steps in the case. Mailed notice (gel,)

AMENDED complaint by United Beauty Brands, LLC against Guangzhou Meidishi Biotechnology Co., Ltd

EXHIBIT by Plaintiff United Beauty Brands, LLC Schedule A regarding amended complaint, [18]

MOTION by Plaintiff United Beauty Brands, LLC for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by United Beauty Brands, LLC in support of motion for miscellaneous relief[20]

DECLARATION of Sarah DeCristofaro regarding memorandum in support of motion[21]

EXHIBIT by Plaintiff United Beauty Brands, LLC Exhibit 2 regarding declaration[22]

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief[20] before Honorable LaShonda A. Hunt on 8/7/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's ex parte motion for TRO [20] is granted as to limited expedited discovery to obtain information to identify Defendant and denied without prejudice in all other respects. Federal Rule 65(b) instructs that a temporary restraining order should only be issued without notice to the other party if (1) "specific facts in an affidavit or a verified complaint clearly show that immediate and irreparable injury, loss, or damage will result to the movant before the adverse party can be heard in opposition" and (2) "the movant's attorney certifies in writing any efforts made to give notice and the reasons why it should not be required." Fed. R. Civ. P. 65(b). The Seventh Circuit has recognized that "[e]x parte temporary restraining orders are most familiar to courts where notice to the adversary party is impossible either because the identity of the adverse party is unknown or because a known party cannot be located in time for a hearing." Am. Can Co. v. Mansukhani, 742 F.2d 314, 322 (7th Cir. 1984) ; see Fed. R. Civ. P. 65(b). Even if notice can be provided, an exception is provided for the "very narrow band of cases in which ex parte orders are proper because notice to the defendant would render fruitless the further prosecution of the action." Mansukhani, 742 F.2d at 322. Here, the adverse party is known and identified on the public docket. Indeed, Plaintiff's filings [23] identify the name of the Chinese corporate entity, as well as its principal place of business and email address used to operate its virtual storefront. Plaintiff therefore has not shown that notice to Defendant is impossible because its identity is unknown or because Defendant cannot be located in time for a hearing. Plaintiff's request for an ex parte TRO is therefore denied. Regarding Plaintiff's request for expedited discovery, Plaintiff must submit a proposed order concerning expedited discovery to proposed_order_hunt@ilnd.uscourts.gov by 8/13/25. The motion hearing set for 8/7/25 [24] is stricken. The Clerk of Court is directed to update the case caption, forthwith, to reflect that the Defendant in this case is "Guangzhou Meidishi Biotechnology Co., Ltd." Mailed notice (gel,)

ORDER AUTHORIZING LEAVE TO CONDUCT EXPEDITED DISCOVERY Signed by the Honorable LaShonda A. Hunt on 8/19/2025. Mailed notice (gel,)