2025-cv-08153

COMPLAINT filed by BlushCrunch Studio LLC; Filing fee $ 405, receipt number AILNDC-23762686.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Andrew D. Burnham

Declaration of Madeline B. Halgren

(Exhibit A)

Exhibit 1

(Exhibit 1)

SEALED EXHIBIT by Plaintiff BlushCrunch Studio LLC Schedule A regarding complaint[1]

Exhibit A

Exhibit 2-1

MOTION by Plaintiff BlushCrunch Studio LLC for leave to file under Seal

(Exhibit 2-2)

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BlushCrunch Studio LLC

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Andrew Daniel Burnham

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Madeline Halgren

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 Thomas M. Durkin. Designated as Magistrate Judge the Honorable Albert Berry, III. Case assignment: Random assignment. (Civil Category 3). (Text entry; no document attached.)

NEW PARTIES: CUIYU, ERXKVS, Eyiran Poster, For my own little shop, likailijingpin, Liu ZhiFa123, MOQIAN, quanzhoujingjijishukaifaquyanchenmaoyi, Tran Handicraft, htc5948816202-8, spd-shop, AIrTee Lab, ArtWoven pillows, BazaarJet, Big Ajins iron sign two, BlissfulBreezeTees, Canvas painting Ten, Carsonow, CHEN KE xin, Chill Threads, ClingCraft Stickers, CLSDHFKJSD, Colorful Styles, CoolNove, COOLSO, Crafted Couture, Eilall, ERRFGSDD, Favouritea, FlashFaveMart clothing, Fortune Studio Eleven, Glitz And Grace, Globe Bazaar Exchange, GraphicScriptThreads, GZ ChenYu Clothing, HHF Custom, ioi blanket, jhqf, Jilu Home textiles, KawaiiNest, Life mix Twelve, lin xiyong, Lindley Loa, LINMERHAO, LIU blanket, M cloth j, MengKe Studio, ModeMint, Monkey Art DIY, MorningCatee, NIJI SHOP, OutfiTrend, PCVB, PLTHEOO, Pure male tall, QuickFind, rhqf, Richy Field, Sen ThreadsWave, Shuttle Retail, SilkSoft, sisiyan, Six six six clothes T, Spark Innovation Solutions, speckle blanket, Styleora, SunBangSplash, Sweet Housemate, SY sticker, TE SinkeeShirts, TerrauMorphg, Textile touch, Theiall nook, TrendTrove clothing, Trendy Pulse, Trendy Transitions, TrueTee, Trustworthy blanket, TUCastle, VogueCraze, W Boutique B, WeaveJoy, Whimsy Crochet, Wildcard Tees, xiaohui blanket, Xiaoqian blanket, Xiyipin, xqlifashion, YUCO home cleaning, ZenMode, zhaozhanyu, hongjun, imeiTuys, LoTiSee Fresh Net, Sharp Cow, wangximinshangmao, wweiLLn and XiangFengYu added to case caption. (Text entry; no document attached.)

MAILED Copyright report to Registrar, Washington DC

MOTION by Plaintiff BlushCrunch Studio LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BlushCrunch Studio LLC in support of motion for temporary restraining order[11]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[12]

DECLARATION of Mariana Ruiz regarding memorandum in support of motion[12]

SEALED EXHIBIT by Plaintiff BlushCrunch Studio LLC Exhibit 2 - Parts 1-2 regarding declaration[14]

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

MEMORANDUM by BlushCrunch Studio LLC in support of motion for miscellaneous relief[16]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[17]

MINUTE entry before the Honorable Thomas M. Durkin: The Court requires that any motion for a temporary restraining order and/or asset freeze is accompanied by a declaration from an attorney of record that provides the following information. First, to demonstrate the immediate harm necessary to grant the drastic remedy of an ex parte temporary restraining order, the declaration must confirm that each named defendant has sold or offered to sell the allegedly infringing product(s) within the last two months and describe the evidence supporting this confirmation. Generally, evidence that a defendant has sold or offered to sell the infringing products within the last two months may include: (1) screenshots of the listings collected within the last two months; (2) screenshots older than two months with an attestation that the listings reflected in the screenshots have been checked within the last two months and were active; or (3) evidence of a purchase by a customer in Illinois within the last two months. Second, as relevant to personal jurisdiction, without which any temporary restraining order or asset freeze would be invalid, the declaration must confirm that each named defendant sold at least one allegedly infringing product to a customer in Illinois and describe the evidence supporting this confirmation. Here, "sold" means that the defendant accepted an order and payment for an allegedly infringing product to be shipped to Illinois. Third, to assure that Court that the rights of defendants who have not yet been served are being appropriately protected, the declaration must identify the case number(s) and assigned judge(s) for any pending case(s) brought by the plaintiff(s) against any of the named defendants, noting whether the intellectual property at issue was the same or different than in this case. If it is the same, the declaration should describe the disposition of the other case. The Court will address any motion for a temporary restraining order only after receipt of the described declaration, which can be filed contemporaneously with the motion. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal [3] is granted. Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [11] is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) [16] is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 7/24/2025. Mailed notice.

Registry Deposit Information Form by BlushCrunch Studio LLC

SURETY BOND in the amount of $ 98,000 posted by BlushCrunch Studio LLC (Document not scanned)

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff BlushCrunch Studio LLC

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

MOTION by Plaintiff BlushCrunch Studio LLC for preliminary injunction

MEMORANDUM by BlushCrunch Studio LLC in support of motion for preliminary injunction[26]

SUMMONS Returned Executed by BlushCrunch Studio LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/4/2025, answer due 8/25/2025.

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction [26] is set for 8/7/2025 at 9:00 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

ATTORNEY Appearance for Plaintiff BlushCrunch Studio LLC by Trevor Christian Talhami

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 8/7/2025. No one was present on behalf of defendants. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 26 is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint 2, Exhibits to the Declaration of Mariana Ruiz 15, and the TRO 21. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. A telephone status hearing is set for 9/12/2025 at 9:30 a.m. To join the telephone conference, dial (650) 479-3207, Access Code 180 815 7648. Throughout the hearing, each speaker will be expected to identify themselves for the record before speaking. Counsel must be in a quiet area while on the line. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 8/7/2025. Mailed notice.

NOTICE of Voluntary Dismissal by BlushCrunch Studio LLC as to certain defendants

ATTORNEY Appearance for Defendant Colorful Styles by Weilian Song

MOTION by Defendant Colorful Styles for extension of time to file answer regarding complaint 1 (Unopposed)

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer 35 is granted. Defendant Colorful Styles is to file an answer to Plaintiff's complaint by 9/15/2025. Mailed notice.

NOTICE of Voluntary Dismissal by BlushCrunch Studio LLC as to a Certain Defendant

MOTION by Plaintiff BlushCrunch Studio LLC for entry of default, MOTION by Plaintiff BlushCrunch Studio LLC for default judgment as to all Defendants with the exception of a certain Defendant

MEMORANDUM by BlushCrunch Studio LLC in support of motion for entry of default, motion for default judgment, 38

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 39

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 9/12/2025 at 9:30 a.m. is converted to a telephone hearing as to the motion for entry of default and default judgment 38. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: The telephone hearing as to the motion for entry of default and default judgment 38 set for 9/12/2025 is reset for 9/11/2025 at 9:30 a.m. Mailed notice.

NOTICE of Voluntary Dismissal by BlushCrunch Studio LLC as to certain defendants