2025-cv-12455

COMPLAINT filed by XYZ Corporation; JURY DEMAND. Filing fee $ 405, receipt number AILNDC-24189012.

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

EXHIBIT by Plaintiff XYZ Corporation EXHIBITS IN SUPPORT regarding complaint 1

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

(Exhibit 3 to the Complaint)

CIVIL Cover Sheet

MOTION by Plaintiff XYZ Corporation to seal PLAINTIFFS MOTION FOR LEAVE TO FILE UNDER SEAL AND PROCEED UNDER PSYDUNEM

(Declaration of Joshua H. Sheskin)

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joshua Howard Sheskin

ATTORNEY Appearance for Plaintiff XYZ Corporation by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff XYZ Corporation by Katherine Marilyn Kuhn

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nazly Aileen Bayramoglu

ATTORNEY Appearance for Plaintiff XYZ Corporation by Nihat Deniz Bayramoglu

CASE ASSIGNED to the Honorable LaShonda A. Hunt. Designated as Magistrate Judge the Honorable Laura K. McNally. Case assignment: Random assignment. (Civil Category 3).

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.

MAILED Copyright report to Registrar, Washington DC

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. On 10/10/25, Plaintiff, proceeding anonymously, commenced this case by filing a redacted complaint 1 along with an unredacted complaint 2, Schedule A [2-1], copyright information [2-2], and evidence of alleged infringement [2-3] under seal. Plaintiff also filed a motion for leave to file under seal and proceed under pseudonym [sic] 4. First, upon review of the copyright infringement complaint and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all 24 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A,No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 24 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. Accordingly, by 10/22/25, Plaintiff must file either a memorandum explaining why joinder is proper or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Second, Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the names of defendants or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 25 C 2937, 2025 WL 2299593 at *7 (N.D. Ill. Aug. 8, 2025) (Kness, J.). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000). Plaintiff has further failed to establish exceptional circumstances which would support its request to proceed under a pseudonym. As the Seventh Circuit has explained, "We have repeatedly voiced our disfavor of parties proceeding anonymously, as anonymous litigation runs contrary to the rights of the public to have open judicial proceedings and to know who is using court facilities and procedures funded by public taxes. To proceed anonymously, a party must demonstrate exceptional circumstances that outweigh both the public policy in favor of identified parties and the prejudice to the opposing party that would result from anonymity." Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); see also Doe v. Loyola Univ. Chicago, 100 F.4th 910, 913 (7th Cir. 2024). The fact that alleged infringers track Counsel's firm to "avoid enforcement and liability," as Plaintiff argues, is far from an exception circumstance. Accordingly, all of Plaintiff's future filings must disclose Plaintiff's identity. The Clerk is directed to (1) update the docket and case caption to reflect that Plaintiff's name is "Wumei Lin," and (2) unseal the documents filed at 2, [2-1], [2-2], and [2-3]. Mailed notice (gel,)

MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to Judge LaShonda A. Hunt. On 10/10/25, Plaintiff, proceeding anonymously, commenced this case by filing a redacted complaint 1 along with an unredacted complaint 2, Schedule A [2-1], copyright information [2-2], and evidence of alleged infringement [2-3] under seal. Plaintiff also filed a motion for leave to file under seal and proceed under pseudonym [sic] 4. First, upon review of the copyright infringement complaint and other filings, the Court questions whether Plaintiff has established sufficient grounds for joinder of all 24 defendants under Fed. R. Civ. P. 20. See Viking Arm AS v. Partnerships & Unincorporated Associations Identified on Schedule A,No. 24 C 1566, 2024 WL 2953105 (N.D. Ill. June 6, 2024). Indeed, Plaintiff filed a form complaint with generic allegations about coordinated counterfeiting activity between 24 defendants without any details whatsoever, which arguably violates the requirements of Federal Rules of Civil Procedure 8 and 10. Accordingly, by 10/22/25, Plaintiff must file either a memorandum explaining why joinder is proper or an amended complaint specifically naming and identifying each defendant being sued and setting forth with more than conclusory statements the alleged infringing activity. Failure to do so will result in the current complaint being dismissed without prejudice and this case being closed. Second, Plaintiff has not established good cause under Local Rule 26.2 or Seventh Circuit precedent to justify sealing the names of defendants or documents pertaining to alleged infringing activity. "Secrecy makes little sense if the goal of the litigation is to protect rightholders' IP interests by obtaining an injunction against defendants' sales of infringing or counterfeit goods." See Eicher Motors Ltd. v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 25 C 2937, 2025 WL 2299593 at *7 (N.D. Ill. Aug. 8, 2025) (Kness, J.). More importantly, this presumption of sealing runs counter to the well-established authority of this Circuit holding that "[m]any a litigant would prefer that the subject matter of a case. be kept from the curious (including its business rivals and customers), but the tradition that litigation is open to the public is of very long standing." See Union Oil Co. of Cal. v. Leavell, 220 F.3d 562, 567-68 (7th Cir. 2000). Plaintiff has further failed to establish exceptional circumstances which would support its request to proceed under a pseudonym. As the Seventh Circuit has explained, "We have repeatedly voiced our disfavor of parties proceeding anonymously, as anonymous litigation runs contrary to the rights of the public to have open judicial proceedings and to know who is using court facilities and procedures funded by public taxes. To proceed anonymously, a party must demonstrate exceptional circumstances that outweigh both the public policy in favor of identified parties and the prejudice to the opposing party that would result from anonymity." Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); see also Doe v. Loyola Univ. Chicago, 100 F.4th 910, 913 (7th Cir. 2024). The fact that alleged infringers track Counsel's firm to "avoid enforcement and liability," as Plaintiff argues, is far from an exception circumstance. Accordingly, all of Plaintiff's future filings must disclose Plaintiff's identity. The Clerk is directed to (1) update the docket and case caption to reflect that Plaintiff's name is "Wumei Lin," and (2) unseal the documents filed at 2, [2-1], [2-2], and [2-3]. Mailed notice (gel,)

AMENDED complaint by XYZ Corporation against The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto

Exhibit 1 to the First Amended Complaint

(Exhibit 2 to the First Amended Complaint)

MINUTE entry before the Honorable LaShonda A. Hunt: In light of Plaintiff's filing of the amended complaint 13, the Clerk is directed to update the docket and case caption to reflect that Defendant is "Hong Kong Xunling Limited D/B/A HTSRTE." By 11/6/25, Plaintiff is ordered to file a status report proposing next steps in this case, if no other appropriate relief has not been sought by that date. Mailed notice (gel,)

STATUS Report IN COMPLIANCE WITH DOCKET NO. 14 by Wumei Lin

MOTION by Plaintiff Wumei Lin to expedite DISCOVERY PURSUANT TO FRCP 45

MEMORANDUM IN SUPPORT OF MOTION FOR EXPEDITED DISCOVERY PURSUANT TO FRCP 45

Declaration of Katherine M Kuhn

NOTICE of Motion by Katherine Marilyn Kuhn for presentment of motion to expedite[16] before Honorable LaShonda A. Hunt on 11/25/2025 at 10:00 AM.

MINUTE entry before the Honorable LaShonda A. Hunt: Plaintiff's motion for leave to conduct expedited discovery [16] is granted. The Court finds that expedited discovery is warranted to obtain Defendant's contact information. Enter Order Authorizing Expedited Discovery. The motion hearing set for 11/25/25 [17] is stricken. If no other relief has been sought, Plaintiff is ordered to file a status report by 12/1/25 updating the Court on the progress of expedited discovery and proposed next steps in the case. Mailed notice

ORDER Authorizing Expedited Discovery signed by the Honorable LaShonda A. Hunt on 11/7/2025. Mailed notice