2026-cv-00698

COMPLAINT filed by Revelyst Adventure Sports LLC; Filing fee $ 405, receipt number AILNDC-24621811.

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Revelyst Adventure Sports LLC Schedule A regarding complaint 1

SEALED EXHIBIT by Plaintiff Revelyst Adventure Sports LLC Exhibit 2 - Part 1 regarding complaint 1

(Exhibit 2-1)

MOTION by Plaintiff Revelyst Adventure Sports LLC for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Revelyst Adventure Sports LLC

Notice of Claims Involving Trademarks by Revelyst Adventure Sports LLC

ATTORNEY Appearance for Plaintiff Revelyst Adventure Sports LLC by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff Revelyst Adventure Sports LLC by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Revelyst Adventure Sports LLC by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff Revelyst Adventure Sports LLC by Rachel Meira Ackerman

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 2).

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.

MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal 4 is granted. Mailed notice.

MOTION by Plaintiff Revelyst Adventure Sports LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Revelyst Adventure Sports LLC in support of motion for temporary restraining order 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

DECLARATION of Paul Mills regarding memorandum in support of motion 16

(Exhibit 1)

SEALED EXHIBIT by Plaintiff Revelyst Adventure Sports LLC Exhibit 2 - Part 1 regarding declaration 18

(Exhibit 2-1)

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

MEMORANDUM by Revelyst Adventure Sports LLC in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

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. Additionally, to the extent Plaintiff also makes a motion for expedited discovery or for an order permitting electronic service of process, Plaintiff should submit a proposed order for that relief that is separate from the proposed order for the TRO and asset restraint. The proposed order for the TRO and asset restraint should name the relevant defendants directly in the order, without reference to Schedule A. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 15 is granted. Motion for electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 20 is granted. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 1/26/2026. Mailed notice.

SEALED Order Authorizing Expedited Discovery and Electronic Service of Process. Signed by the Honorable Thomas M. Durkin on 1/26/2026. Mailed notice.

Registry Deposit Information Form by Revelyst Adventure Sports LLC

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

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

SURETY BOND in the amount of $ 14,000.00 posted by Revelyst Adventure Sports LLC (Document not scanned).

MOTION by Plaintiff Revelyst Adventure Sports LLC for extension of time of Temporary Restraining Order

MEMORANDUM by Revelyst Adventure Sports LLC in support of extension of time 30

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 31

MINUTE entry before the Honorable Thomas M. Durkin: Ex parte motion to extend the Temporary Restraining Order 30 is granted. The Temporary Restraining Order entered on 1/26/2026 is extended by a period of fourteen (14) days until 2/23/2026. Mailed notice.

MOTION by Plaintiff Revelyst Adventure Sports LLC for preliminary injunction

(Exhibit A)

MEMORANDUM by Revelyst Adventure Sports LLC in support of motion for preliminary injunction 35

DECLARATION of Trevor C. Talhami regarding memorandum in support of motion 36

SUMMONS Returned Executed by Revelyst Adventure Sports LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/6/2026, answer due 2/27/2026.

Declaration of Rachel M. Ackerman

(Exhibit A)

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion for preliminary injunction 35 is set for 2/12/2026 at 9:15 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.

EXHIBIT by Plaintiff Revelyst Adventure Sports LLC Amended Exhibit A regarding summons returned executed, 38, MOTION by Plaintiff Revelyst Adventure Sports LLC for preliminary injunction 35

ATTORNEY Appearance for Plaintiff Revelyst Adventure Sports LLC by Kahlia Roe Halpern

MOTION for Leave to Appear Pro Hac Vice on behalf of Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com) by David D Lin; Filing fee $ 150, receipt number AILNDC-24716103.

MINUTE entry before the Honorable Thomas M. Durkin: Motion to appear pro hac vice 42 is granted. Attorney David D. Lin for Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com) and Defendant 31 (tedlook.com) added. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 2/12/2026. Mr. Lin was present on behalf of certain defendants. No other defendants appeared. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction [35] is granted as to non-appearing defendants. Plaintiff's counsel is to submit an updated Preliminary Injunction Order. The Clerk's office is directed to unseal Schedule A to the Complaint [2], Exhibit 2 to the Complaint [3], Exhibits to the Declaration of Paul Mills [19], the TRO [25], and the Order Authorizing Expedited Discovery and Electronic Service of Process [26]. 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. The TRO is extended through 2/23/2026 as to Mr. Lin's clients. A joint status report is due by 2/23/2026. A telephone status hearing as to all other defendants is set for 3/26/2026 at 9:15 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 2/12/2026. Mailed notice.

NEW PARTIES: BYCUSTOMER, manmanju, aht-shop, fa-458228, hl-shop 1, HuaLei, l'y021, lqdstd, Noble Essence Atelier, CARA Womens Clothing, Clothes Cloud, Graffix SHOP, Hi Customer, HypeHem, Jun Jun Bag, Little Beauty Tshirt, LIU ONE FASHION, lucky girl wears, SRPOD SHOP, VIVI BIG GIRLS, World Press, WW BEAUTY, Breakthrough Style, SNOW FALL Company, commercesigns.com, expoionus.com, foxracing-us.shop, opentip.com, powerridezone.com, techwearclub.com, tedlook.com and zenifur.com added to case caption.

MOTION by Plaintiff Revelyst Adventure Sports LLC to compel

Exhibit 1

DECLARATION of Trevor C. Talhami regarding motion to compel[46]

MINUTE entry before the Honorable Thomas M. Durkin: A telephone hearing as to the motion to compel [46] is set for 3/2/2026 at 9:15 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 Defendants Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com) by Anna Iskikian

RESPONSE by Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com)in Opposition to MOTION by Plaintiff Revelyst Adventure Sports LLC to compel [46]

Declaration of David D. Lin

Exhibit 1

Exhibit 2

Exhibit 3

STATUS Report Pursuant to [44] (Joint) by Revelyst Adventure Sports LLC

MINUTE entry before the Honorable Thomas M. Durkin: By agreement of the parties, the TRO as to Defendants expoionus.com (Defendant No. 26), techwearclub.com (Defendant No. 30), and tedlook.com (Defendant No. 31) is extended until the Court rules on Plaintiff's pending Motion for a Preliminary Injunction [35]. By 2/27/2026, Defendants are to provide information regarding Defendants' sales revenue and costs arising from Defendants' sales of the allegedly infringing goods. Defendants are to file their opposition to Plaintiff's pending Motion for a Preliminary Injunction [35] by 2/27/2026, along with a motion to set aside or modify the asset restraint, for improper joinder, and to increase the bond. Plaintiff's response is due by 3/13/2026. Defendants' reply is due by 3/18/2026. Mailed notice.

MOTION by Defendants Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com) for protective order on consent

Text of Proposed Order

NOTICE of Voluntary Dismissal by Revelyst Adventure Sports LLC as to a Certain Defendant

MINUTE entry before the Honorable Thomas M. Durkin: Motion for agreed confidentiality order [53] is granted. Mailed notice.

AGREED Confidentiality Order. Signed by the Honorable Thomas M. Durkin on 2/26/2026. Mailed notice.

MOTION by Defendants Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com)Dissolve Temporary Asset Restraint, Increase Bond, and Sever for Improper Joinder

MEMORANDUM by Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com) in support of motion for miscellaneous relief[57] and in Opposition to Plaintiff's Motion for Preliminary Injunction

DECLARATION of Yee Wai Leuk regarding motion for miscellaneous relief[57], memorandum in support of motion, [58]

Exhibit 1

Exhibit 2

Exhibit 3

ANSWER to Complaint by Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com)

ATTORNEY Appearance for Defendant BYCUSTOMER by Yong Chen

MOTION by Defendant BYCUSTOMER for extension of time to file answer regarding complaint[1], CONSENTED

MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for extension of time to answer [62] is granted. Defendant BYCUSTOMER is to answer or otherwise respond to Plaintiff's Complaint by 3/20/2026. Mailed notice.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 3/2/2026. Briefing schedule on the Motion to Dissolve the Temporary Asset Restraint, Increase Bond, and Sever for Improper Joinder [57] was set at docket entry [52]. The motion to compel [46] is entered and continued. A telephone status hearing is set for 3/23/2026 at 9:15 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 Defendants Defendant 26 (expoionus.com), Defendant 30 (techwearclub.com), Defendant 31 (tedlook.com) by Christopher Paul Keleher

MOTION by Plaintiff Revelyst Adventure Sports LLC for entry of default, MOTION by Plaintiff Revelyst Adventure Sports LLC for default judgment as to all Defendants with the exception of certain Defendants

Exhibit A

MEMORANDUM by Revelyst Adventure Sports LLC in support of motion for entry of default, motion for default judgment, [66]

Exhibit 1

Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[67]

Exhibit 1

MINUTE entry before the Honorable Thomas M. Durkin: The telephone status hearing set for 3/26/2026 at 9:15 a.m. is vacated. A telephone hearing as to the motion for entry of default and default judgment [66] is set for 3/23/2026 at 9:15 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.

NOTICE of Voluntary Dismissal by Revelyst Adventure Sports LLC as to a Certain Defendant

ATTORNEY Appearance for Defendants expoionus.com, techwearclub.com, tedlook.com by Lan Li