2025-cv-08799

COMPLAINT (Redacted) filed by Intercontinental Great Brands, LLC; Jury Demand. Filing fee $ 405, receipt number AILNDC-23805086.

(Exhibit Exhibit 2 to the Redacted Complaint)

Exhibit Exhibit 1 to the Unredacted Complaint

Exhibit Exhibit 2 to the Redacted First Amended Complaint

Exhibit Exhibit 1 to the Unredacted First Amended Complaint

Exhibit Exhibit 1

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Exhibit 1 to the Redacted Complaint

Exhibit Exhibit 2 to the Unredacted Complaint

(Exhibit Redline Copy of the Redacted First Amended Complaint)

Exhibit Exhibit 2 to the Unredacted First Amended Complaint

Exhibit Exhibit 2

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Schedule A to the Redacted Complaint

(Exhibit Schedule A to the Unredacted Complaint)

Exhibit Schedule A to the Unredacted First Amended Complaint

(Exhibit Exhibit 3)

CIVIL Cover Sheet

(Exhibit Redline Copy of the Unredacted First Amended Complaint)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Complaint (Unredacted)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Notice of Trademark Claim

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Intercontinental Great Brands, LLC

MOTION by Plaintiff Intercontinental Great Brands, LLC to seal document sealed document 2, sealed document 3, sealed document 6, sealed document, 5

ATTORNEY Appearance for Plaintiff Intercontinental Great Brands, LLC by Brandon Matthew Beymer

ATTORNEY Appearance for Plaintiff Intercontinental Great Brands, LLC by Daliah Saper

CASE ASSIGNED to the Honorable Georgia N Alexakis. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Georgia N Alexakis: The Court grants plaintiff's motion for leave to file certain documents under seal 8. Upon review of the complaint, the Court sua sponte raises the propriety of joining 216 defendants in a single action. By 8/13/25, plaintiff must file a supplemental memorandum addressing the propriety of joinder in light of this Court's orders in Bug Art Limited v. The Partnerships, 24 CV 7777, Dkt. 28 (N.D. Ill. Oct. 28, 2024), and Anagram International v. The Partnerships, 24 CV 12194, Dkt. 87 (N.D. Ill. Feb. 21, 2025). In the alternative, plaintiff has leave to file an amended complaint by 8/13/25 with a smaller subset of defendants along with a memorandum explaining why that smaller subset of defendants is properly joined. No motion for an ex parte temporary restraining order should be filed in this matter without counsel first consulting this Court's order in Wham-O Holding v. The Partnerships, 24 CV 12523, Dkt. 39 (N.D. Ill. Feb. 20, 2025).

MINUTE entry before the Honorable Georgia N Alexakis: Initial status hearing is set for 10/2/25 at 9:30 a.m. in person in Courtroom 1719. By 9/25/25, 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.

First AMENDED complaint by Intercontinental Great Brands, LLC against The Partnerships and Unincorporated Associations Identified on Schedule A (Redacted)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Exhibit 1 to the Redacted First Amended Complaint

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Schedule A to the Redacted First Amended Complaint

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC First Amended Complaint (Unredacted)

MOTION by Plaintiff Intercontinental Great Brands, LLC for temporary restraining order

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for temporary restraining order 19 (Redacted)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC MEMORANDUM in support of motion for temporary restraining order 19 (Unredacted)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC Declaration of Plaintiff in Support of Motion for Temporary Restraining Order

MOTION by Plaintiff Intercontinental Great Brands, LLC for service by publication

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for service by publication 23

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for temporary restraining order 19, motion for service by publication 23 before Honorable Georgia N. Alexakis on 8/13/2025 at 09:30 AM.

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for temporary restraining order 19, motion for service by publication 23 before Honorable Georgia N. Alexakis on 8/14/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N. Alexakis: Plaintiff's motion for an ex parte temporary restraining order is denied 19. Plaintiff's memorandum in support of its motion for a TRO asserts that plaintiff is experiencing "ongoing" and "immediate" harm owing to defendants' alleged infringement of plaintiff's intellectual property. See 20 at 2, 5, 10, 11. This representation is critical in light of Rule 65(b)(1)(A)'s requirement that a court "issue a temporary restraining order without written or oral notice to the adverse party or its attorney only if 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." Fed. R. Civ. P. 65(b). Yet plaintiff has submitted documents reflecting only that defendant offered for sale the allegedly infringing products in January 2025, which is eight months ago. [22-3]. The Court further observes that plaintiff requests a blanket freeze of defendants' assets. That request fails to identify the property or proceeds plaintiff seeks to enjoin with a sufficient degree of specificity, where, based on the Court's review of the third-party seller's website, the defendant appears to sell products unrelated to plaintiff's products. The Court previously directed plaintiff to review its order in Wham-O Holding, Ltd. and Intersport Corp. d/b/a Wham-O v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified in Schedule A, 24 CV 12523, ECF No. 39 (N.D. Ill. Feb. 20, 2025), before filing any motion for a temporary restraining order. In Wham-O Holding, the Court discussed the deficiencies plaintiff has exhibited here. By 8/20/25, plaintiff is directed to show cause why this matter should not be dismissed with prejudice given plaintiff's failure to abide by the Court's order. Plaintiff's motion for electronic service of process 23 remains under advisement in the meantime. No appearance is required on 8/14/25.

RESPONSE by Plaintiff Intercontinental Great Brands, LLC to order on motion for temporary restraining order, terminate hearings, 27 Response to Order to Show Cause

MOTION by Plaintiff Intercontinental Great Brands, LLC for temporary restraining order

MEMORANDUM by Intercontinental Great Brands, LLC in support of motion for temporary restraining order 29 (Redacted)

SEALED DOCUMENT by Plaintiff Intercontinental Great Brands, LLC MEMORANDUM in support of motion for temporary restraining order 29 (Unredacted)

DECLARATION of Brandon Beymer regarding motion for temporary restraining order 29

NOTICE of Motion by Brandon Matthew Beymer for presentment of motion for temporary restraining order 29, motion for service by publication 23 before Honorable Georgia N. Alexakis on 8/25/2025 at 09:30 AM.

MINUTE entry before the Honorable Georgia N. Alexakis: The Court has reviewed plaintiff's response to its rule to show cause and, in light of the response, discharges the rule to show cause. The Court grants plaintiff's motion for electronic service of process 23 and plaintiff's renewed ex parte motion for entry of a temporary restraining order, a temporary asset restraint, and expedited discovery 29 is granted. No appearance is required on 8/25/25. 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. The temporary asset restraint is limited only to proceeds from sales of products using the specific trademarks at issue. 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 $10,000 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 8/22/25.

MOTION by Plaintiff Intercontinental Great Brands, LLC for preliminary injunction