2025-cv-08001

COMPLAINT filed by LeChong Maoyi Xiantao Youxiangongsi ; Jury Demand. Filing fee $ 405, receipt number AILNDC-23749972.

Exhibit A

Declaration

SEALED EXHIBIT by Plaintiff LeChong Maoyi Xiantao Youxiangongsi Schedule A regarding complaint 1

Exhibit D

Declaration

SEALED EXHIBIT by Plaintiff LeChong Maoyi Xiantao Youxiangongsi Exhibit B regarding complaint 1

(Exhibit E)

Exhibit A

SEALED EXHIBIT by Plaintiff LeChong Maoyi Xiantao Youxiangongsi Exhibit C regarding complaint 1

Exhibit B

ATTORNEY Appearance for Plaintiff LeChong Maoyi Xiantao Youxiangongsi by Ge Lei

(Exhibit C)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by LeChong Maoyi Xiantao Youxiangongsi

MOTION by Plaintiff LeChong Maoyi Xiantao Youxiangongsi for temporary restraining order

MEMORANDUM by LeChong Maoyi Xiantao Youxiangongsi in support of motion for temporary restraining order 8

MOTION by Plaintiff LeChong Maoyi Xiantao Youxiangongsi for Alternative Service

MOTION by Plaintiff LeChong Maoyi Xiantao Youxiangongsi to seal documents

CASE ASSIGNED to the Honorable Georgia N Alexakis. 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.)

Check BOND in the amount of $ 1,000 posted by LeChong Maoyi Xiantao Youxiangongsi. Receipt 100023093. (Text entry; no document attached.)

NEW PARTIES: ZenTroveUSA added to case caption. (Text entry; no document attached.)

NOTICE of Motion by Ge Lei for presentment of motion for miscellaneous relief 10, motion for temporary restraining order 8, motion to seal 11 before Honorable Georgia N Alexakis on 7/24/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 9/22/25 at 9:30 a.m. in person in Courtroom 1719. By 9/15/25, 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.

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion to seal 11, motion for electronic service of process 10, and ex parte motion for entry of a temporary restraining order 8. No appearance is required on 7/24/25. Based on plaintiff's written submissions, the Court finds that plaintiff has established (1) a likelihood of success on the merits; (2) the harm to plaintiff is irreparable and cannot be fully compensated by money damages; (3) an injunction is in the public interest because of the consumer confusion caused by counterfeit goods and infringement interferes with plaintiff's ability to control its intellectual property; and (4) there is no countervailing harm to defendants from an order directing them to stop infringement. Plaintiff's written submissions also establish that if defendants were informed of this proceeding before a TRO could issue, assets representing proceeds from the sale of the infringing products would likely be redirected, defeating plaintiff's interests in stopping the infringement and obtaining an accounting. Expedited discovery is warranted to identify defendant and implement the asset freeze. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective way to communicate with these online marketplace defendants. The Court decides these motions, though, without the benefit of adversarial presentation. If defendant were to appear and object, the Court is willing revisit issues related to, among other topics, the asset restraint, personal jurisdiction, and electronic service of process. A $1,000 bond is sufficient to secure the injunctive relief. Enter order, as modified by the Court.

SEALED Temporary Restraining Order Signed by the Honorable Georgia N Alexakis on 7/23/25.

SUMMONS Submitted (Court Participant) for defendant(s) The Entity or Individual Identified in Schedule A by Plaintiff LeChong Maoyi Xiantao Youxiangongsi

MOTION by Plaintiff LeChong Maoyi Xiantao Youxiangongsi for preliminary injunction

MEMORANDUM by LeChong Maoyi Xiantao Youxiangongsi in support of motion for preliminary injunction 18

NOTICE of Motion by Ge Lei for presentment of motion for preliminary injunction 18 before Honorable Georgia N. Alexakis on 8/5/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N. Alexakis: Before the Court is plaintiff's motion for entry of a preliminary injunction 18, which the Court takes under advisement. Defendant is advised that the Court will consider the motion unopposed if it does not file a notice of objection by 8/11/25. Consistent with Federal Rule of Civil Procedure 65(a), plaintiff must serve a copy of its motion for entry of a preliminary injunction and this minute order upon all defendants within one business day and promptly file proof of that service. The Court resets the hearing on plaintiff's motion for a preliminary injunction from 8/5/25 to 8/14/25 at 9:30 a.m.

SUMMONS Submitted (Court Participant) for defendant(s) The Entity or Individual Identified in Schedule A by Plaintiff LeChong Maoyi Xiantao Youxiangongsi

CERTIFICATE of Service by Ge Lei on behalf of LeChong Maoyi Xiantao Youxiangongsi

SUMMONS Issued (Court Participant) as to Defendant The Entity or Individual Identified in Schedule A

SUMMONS Returned Executed by LeChong Maoyi Xiantao Youxiangongsi as to The Entity or Individual Identified in Schedule A on 8/1/2025, answer due 8/22/2025.

REGISTRY Deposit Information Form by LeChong Maoyi Xiantao Youxiangongsi (Received at the Intake Counter on 8/11/25.)

MINUTE entry before the Honorable Georgia N. Alexakis: Before the Court is plaintiff's motion for a preliminary injunction [18], which the Court now considers unopposed because no defendant filed a notice of objection by the 8/11/25 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. Enter Preliminary Injunction Order, as modified by the Court. Plaintiff's counsel is directed to ensure that all defendants listed on the Schedule A [2] are added to the court's docket by 8/19/25. The Clerk is requested to unseal any previously sealed documents. Summons were returned executed on 8/1/25 and any response to the complaint is due by 8/22/25 [33]. If no defendant appears before then, by 9/5/25, plaintiff is directed to file any motion for entry of default judgment pursuant to Federal Rule of Civil Procedure 55(a) and to notice the motion up for presentment before the Court. If there are any remaining defendants against whom default and default judgment are not being sought, plaintiff is ordered to file by the same date a status report identifying each defendant against whom this case is proceeding and state whether the parties anticipate a settlement or further litigation. No appearance is required on 8/14/25. The Court vacates the 9/15/25 deadline for filing a joint initial status report and the 9/22/25 initial status hearing.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Georgia N. Alexakis on 8/13/25.

MOTION by Plaintiff LeChong Maoyi Xiantao Youxiangongsi for entry of default

MINUTE entry before the Honorable Georgia N. Alexakis: Plaintiff seeks entry of default as to Defendant No. 1, the only defendant in this matter. Defendant No. 1 has failed either to plead or to otherwise appear to defend against this action. Accordingly, default against Defendant No. 1 is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment by the Defaulting Defendant must be filed on or before 9/18/25. Plaintiff must serve this minute order upon the Defaulting Defendant within one business day of its entry on the docket and must promptly file proof of that service. The Court re-sets the hearing on plaintiff's motion seeking default judgment as to the Defaulting Defendant from 9/11/25 to 9/25/25 at 9:30 a.m. Mailed notice.