2025-cv-08445

COMPLAINT filed by The Liverpool Football Club and Athletic Grounds Limited; Filing fee $ 405, receipt number AILNDC-23785169.

Exhibit 1

Exhibit 1

Exhibit A

Declaration of Jennifer V. Nacht

(Exhibit A)

(Exhibit A)

Exhibit 1

(Exhibit 1)

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Schedule A regarding complaint[1]

Exhibit A

(Exhibit 2)

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Liverpool Football Club and Athletic Grounds Limited

Notice of Claims Involving Trademarks by The Liverpool Football Club and Athletic Grounds Limited

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff The Liverpool Football Club and Athletic Grounds Limited by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Matthew F. Kennelly. 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: Always the 1st Choice, jin ze rui mao yi, Atopos Serendipity, AWRFQWWVFG, BETTER SHOP V, Beyou special clothes, Bin Ge Car Stickers, bin homes, Chic Uniquess, CTSM, Dada Exquisite Fashion, Daily blanket, DuzhijuanCar Stickers, EESCVI, Elegant blacksmith, Emily Blanket, Ethereal Fortune, Full Happiness, GlitCone, gsddfh juhu, Happy Choice Stickers, HarmonyHues, IJUGN, individualizationer, KFDGBFDLFCK poster art shop, Life Cozy, Lihuang Car Stickers, Ling blanket, Lowkey Future, LushLoom, Luxe Loving, Mamba Car Stickers, PQ Wall Art Tin Sign Decor, Qiu blanket, QuantumMart, Quiet corner wall art, Roky Anime Wall Art Poster, Rong blanket, Smile Blankets, StyleOrbit, Three dahua, WGYing, Woqu blanket, wuYanqing car sticker, wuzhognxine, wuzhongxinc, xiaozhi blanket and Zhuangjia blanket added to case caption. (Text entry; no document attached.)

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

DECLARATION of Paul Dicken regarding memorandum in support of motion[14]

SEALED EXHIBIT by Plaintiff The Liverpool Football Club and Athletic Grounds Limited Exhibit 2 regarding declaration[16]

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion to file under seal 3 and motion for electronic service of process 18 are granted. Plaintiff's motion for entry of an ex parte temporary restraining order (etc.) 13 is also granted. Enter Sealed Ex Parte Temporary Restraining Order. Telephonic preliminary injunction hearing is set for 8/11/2025 at 8:50 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction or motion to extend TRO is to be filed by 8/6/2025. The Court may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing. Mailed notice.

SEALED ORDER: Signed by the Honorable Matthew F. Kennelly on 7/28/2025.

Registry Deposit Information Form by The Liverpool Football Club and Athletic Grounds Limited

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and Unincorporated Associations Identified on Schedule A by Plaintiff The Liverpool Football Club and Athletic Grounds Limited

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

CIVIL BOND in the amount of $ 10,000 posted by The Liverpool Football Club and Athletic Grounds Limited (Document not scanned)

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for extension of time of Temporary Restraining Order

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of extension of time[27]

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion[28]

SUMMONS Returned Executed by The Liverpool Football Club and Athletic Grounds Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/5/2025, answer due 8/26/2025.

MINUTE entry before the Honorable Matthew F. Kennelly: Plaintiff's motion for extension of the temporary restraining order [27] is granted; the ex parte TRO entered by the Court on 7/28/2025 is extended through 8/25/2025. The telephonic preliminary injunction hearing set for 8/11/2025 is vacated and reset to 8/25/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Motion for preliminary injunction is to be filed by 8/20/2025. The Court may deny entry of a preliminary injunction if there is an insufficient interval between electronic service of summons and the preliminary injunction hearing.

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for preliminary injunction

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for preliminary injunction 32

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 33

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to certain defendants

MINUTE entry before the Honorable Matthew F. Kennelly: No defendant in this case has filed an appearance or an answer or a response to the motion for preliminary injunction. The telephonic preliminary injunction hearing set for 8/25/2025 is vacated. Plaintiff's motion for entry of a preliminary injunction is granted 32. Enter Preliminary Injunction Order. The Clerk is directed to unseal all documents that were previously filed under seal. Law Firm Greer, Burns and Crain, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a telephonic status hearing on 10/24/2025 at 8:55 AM. The following call-in number will be used for the hearing: 650-479-3207; access code 2305-915-8729. Plaintiff is directed to file a status report on 10/17/2025. Mailed notice.

PRELIMINARY INJUNCTION ORDER: Signed by the Honorable Matthew F. Kennelly on 8/22/2025. Mailed notice.

ATTORNEY Appearance for Defendants HarmonyHues, LushLoom by Xuanjie Wang

MOTION by Defendants HarmonyHues, LushLoom for extension of time to file answer regarding complaint[1]

MINUTE entry before the Honorable Matthew F. Kennelly: Motion by defendants HarmonyHues and LushLoom for extension of time 39 is granted; response to complaint is to be filed by 9/15/2025.

NOTICE of Voluntary Dismissal by The Liverpool Football Club and Athletic Grounds Limited as to Certain Defendants

MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for entry of default, MOTION by Plaintiff The Liverpool Football Club and Athletic Grounds Limited for default judgment as to all Defendants with the exception of certain Defendants

MEMORANDUM by The Liverpool Football Club and Athletic Grounds Limited in support of motion for entry of default, motion for default judgment, 42

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 43