最近更新:2025-02-20
更新

2024-cv-03459

Safe&Safety Inc. et al v. The Individuals and Entities Identified on Schedule A to The Complaint

日期:04/29/2024

法院:伊利诺伊州北区法院

品牌:

律所:

日期 描述
04/07/2025 ATTORNEY Appearance for Counter Claimants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD., Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. by Jie Li
03/13/2025 MINUTE entry before the Honorable John F. Kness: Telephonic motion hearing held on 3/13/2025. For the reasons stated on the record, Plaintiff's motion to strike attorney's lien 69 is denied. Movant ShinyRise PLLC's motion for leave 71 is granted. Movant ShinyRise PLLC's motion to strike 72 is granted in part. Exhibits on the docket at docket entry 70-1and 70-2 are stricken (to the extent they have not already been withdrawn by Plaintiff). Mailed notice. Modified on 3/14/2025.
02/21/2025 MINUTE entry before the Honorable John F. Kness: To accommodate a jury trial, the hearing set for 2/27/2025 is reset to 3/13/2025 at 9:30 A.M. The parties are to use the following call-in number: 1-855-244-8681 and enter Access Code: 2315 003 3696. Press # when prompted for an attendee number. The public and media representatives may have access to the hearing via the same number. Audio recording of the hearing is not permitted; violations of this prohibition may result in sanctions. Participants are directed to keep their device muted when they are not speaking. Mailed notice.
01/14/2025 NOTICE by Christina Joanne Blackfor Lesko of Change of Address and Firm Name
01/10/2025 MINUTE entry before the Honorable John F. Kness: Movant ShinyRise PLLC's Motion to strike is fully briefed and under advisement. Accordingly, the status hearing set for 1/14/2025 is reset to 2/27/2025 at 9:00 A.M. The parties are to use the following call-in number: 1-855-244-8681 and enter Access Code: 2315 003 3696. Press # when prompted for an attendee number. The public and media representatives may have access to the hearing via the same number. Audio recording of the hearing is not permitted; violations of this prohibition may result in sanctions. Participants are directed to keep their device muted when they are not speaking. Mailed notice.
12/27/2024 ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.
12/10/2024 SUR-REPLY by Movant ShinyRise PLLC to reply to response to motion, [88]
附件:
1:Declaration of Ms. Gong
12/03/2024 MINUTE entry before the Honorable John F. Kness: In-person status hearing held 12/3/2024. Oral argument heard on Plaintiff's motion to strike attorney's lien [69]. As discussed on the record, Defendant ShinyRise PLLC is given leave to file a sur-response, limited to no more than 5 pages (not including an anticipated declaration), to Plaintiff's motion to strike on or before 12/10/2024. A telephonic tracking status hearing is set for 1/14/2025 at 9:30 A.M. The parties are to use the following call-in number: 1-855-244-8681, Access Code: 2315 003 3696. The public and media representatives may have access to the hearing via the same number. Audio recording of the hearing is not permitted; violations of this prohibition may result in sanctions. Participants are directed to keep their device muted when they are not speaking. Mailed notice.
12/02/2024 ATTORNEY Appearance for Movant ShinyRise PLLC by Sen Wang
12/02/2024 REPLY by Shenzhen ZhengMi Technology Co. to MOTION for leave to file[85], response in opposition to motion[84] to strike attorneys lien
附件:
1:Exhibit A - Declaration of Plaintiffs by its Agent, Ziyang Bao
11/29/2024 MINUTE entry before the Honorable John F. Kness: Plaintiff's motion [85] for leave to file a reply brief is granted. Plaintiff must file the reply brief as a separate docket item within three business days. Mailed notice
11/21/2024 Pursuant to Judge Kness' Motions Policy STATEMENT by Shenzhen ZhengMi Technology Co.
11/21/2024 REPLY by Shenzhen ZhengMi Technology Co. to response in opposition to motion[84] Motion for Leave to File Reply
附件:
1:Exhibit 1 - Plaintiff's Reply to ShinyRise, PLLC's Response to Motion
10/31/2024 RESPONSE by ShinyRise PLLCin Opposition to MOTION by Plaintiff Shenzhen ZhengMi Technology Co. to strike notice of filing[37] Attorneys Lien [69]
10/29/2024 TRANSCRIPT OF PROCEEDINGS held on 10/3/2024 before the Honorable John F. Kness. Court Reporter Contact Information: Nancy LaBella, Nancy_LaBella@ilnd.uscourts.gov, 312-435-6890. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 11/19/2024. Redacted Transcript Deadline set for 11/29/2024. Release of Transcript Restriction set for 1/27/2025.
10/29/2024 TRANSCRIPT OF PROCEEDINGS held on 7/10/2024 before the Honorable John F. Kness. Court Reporter Contact Information: Nancy LaBella, Nancy_LaBella@ilnd.uscourts.gov, 312-435-6890. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 11/19/2024. Redacted Transcript Deadline set for 11/29/2024. Release of Transcript Restriction set for 1/27/2025.
10/09/2024 NOTICE of Voluntary Dismissal by Safe&Safety Inc., Shenzhen ZhengMi Technology Co. against Defendant DLUMOND
10/04/2024 MINUTE entry before the Honorable John F. Kness: In-person motion hearing held 10/3/2024. The Courts directs the Clerk's Office to seal Exhibit B to Plaintiff's memorandum in support of motion to strike [70]. Counsel for Plaintiff is directed to file a redacted version of the exhibit promptly on the docket. Attorney Zheng Gong is given leave to file a response to Plaintiff's Motion to Strike the Attorney's Lien by 10/31/2024. An in-person status hearing is set for 12/3/2024 at 10:00 A.M. Mailed notice.
10/03/2024 MEMORANDUM by Safe&Safety Inc., Shenzhen ZhengMi Technology Co. in support of motion to strike[69] Attorneys Lien
附件:
1:Exhibit B - February 25, 2024 Agreement for Legal Services
2:Exhibit A - July 3, 2024 Letter from Shiny Rise PLLC
09/18/2024 MINUTE entry before the Honorable John F. Kness: Defendant DLUMOND's Unopposed Motion to Extend Deadline to Answer or Otherwise Respond [77] is granted. Defendant DLUMOND must answer or otherwise plead to Plaintiff's complaint on or before 10/4/2024. Mailed notice.
09/13/2024 MOTION by Defendant DLUMOND for extension of time to file answer regarding complaint[1]
09/13/2024 ATTORNEY Appearance for Defendant DLUMOND by Timothy Tiewei Wang
08/29/2024 STATEMENT of defense by Ning Bo Dong Ying Ji Li Electronics LTD. (Envelope postmarked 08/02/2024) (Received by mail in the Clerk's Office on 08/29/2024)
09/04/2024 MINUTE entry before the Honorable John F. Kness: This matter is set for an in-person motion hearing on pending motions [69], [71], [72] on 10/3/2024 at 10:00 A.M. in Courtroom 2125. Lead counsel is directed to appear at the hearing. Mailed notice. Modified on 9/4/2024.
09/03/2024 NOTICE of Voluntary Dismissal by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
08/24/2024 MOTION by Movant ShinyRise PLLC to strike MOTION by Plaintiff Shenzhen ZhengMi Technology Co. to strike notice of filing[37] Attorneys Lien [69], memorandum in support of motion, [70]
08/24/2024 MOTION by Movant ShinyRise PLLC for leave to file Motion to Strike
08/23/2024 MEMORANDUM by Shenzhen ZhengMi Technology Co. in support of motion to strike[69] Attorneys Lien
附件:
1:Exhibit B-February 25, 2024 Agreement for Legal Services
2:Exhibit A-July 3, 2024 Letter from Shiny Rise PLLC
08/23/2024 MOTION by Plaintiff Shenzhen ZhengMi Technology Co. to strike notice of filing[37] Attorneys Lien
08/23/2024 ATTORNEY Appearance for Plaintiff Shenzhen ZhengMi Technology Co. by Thomas John Nitschke
08/22/2024 Answer to Counterclaims by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
08/20/2024 MOTION by Plaintiff Shenzhen ZhengMi Technology Co. for leave to appear as Retained Counsel
附件:
1:Attorney Appearance Form
08/05/2024 ANSWER to counterclaim by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
08/05/2024 ANSWER to counterclaim by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
08/02/2024 AMENDED answer to complaint[62] by Defendants Grimtron's Safety Store, Karmila, MD Madoats, and Z Zljuan
07/30/2024 ANSWER to Complaint with Jury Demand by Grimtron's Safety Store, Karmila, MD MADOATS, Z ZLJUAN
07/29/2024 MINUTE entry before the Honorable John F. Kness: Motion by counsel to withdraw as attorney [60] is granted. Attorney Christopher Paul Keleher is withdrawn as counsel of record. Mailed notice.
07/27/2024 MOTION by Attorney Christopher Keleher to withdraw as attorney for Grimtron's Safety Store, Karmila, MD MADOATS, Z ZLJUAN. No party information provided
07/25/2024 ATTORNEY Appearance for Defendants Grimtron's Safety Store, Karmila, MD MADOATS, Z ZLJUAN by Pete Scott Wolfgram
07/24/2024 NOTICE of Voluntary Dismissal by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
07/22/2024 SUMMONS Returned Executed by Shenzhen ZhengMi Technology Co., Safe&Safety Inc. as to Shenzhen Mengdan Technology Co., Ltd. on 7/17/2024, answer due 8/7/2024.
附件:
1:Exhibit A
2:Declaration Bo Yang
07/17/2024 STATUS Report Joint Status Report by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
07/15/2024 NOTICE of Voluntary Dismissal by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.
07/15/2024 ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by Dongguan Huaxun Plastic Technology Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., Shenzhen Yunli Design Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD. against Safe&Safety Inc., Shenzhen ZhengMi Technology Co. by Dongguan Huaxun Plastic Technology Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., Shenzhen Yunli Design Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD.
附件:
1:Exhibit 20 Prosecution documents
2:Exhibit 21 Recall Information
3:Exhibit 19 Invalidity Chart
4:Exhibit 18 Invalidity Chart
5:Exhibit 17 Invalidity Chart
6:Exhibit 16 Invalidity Chart
7:Exhibit 15 Prior Art
8:Exhibit 14 Prior Art
9:Exhibit 13 Prior Art
10:Exhibit 12 Prior Art
11:Exhibit 11 Prior Art
12:Exhibit 10 Invalidity Chart
13:Exhibit 9 Prior Art
14:Exhibit 8 Invalidity Chart
15:Exhibit 7 Prior Art
16:Exhibit 6 Invalidity Chart
17:Exhibit 5 Prior Art
18:Exhibit 4 Invalidity Chart
19:Exhibit 3 Prior Art
20:Exhibit 2 Invalidity Chart
21:Exhibit 1 Prior Art
07/15/2024 SUMMONS Issued as to Defendant The Individuals and Entities Identified on Schedule A to The Complaint
07/15/2024 ATTORNEY Appearance for Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. by Maia H. Harris
07/15/2024 ANSWER to Complaint with Jury Demand, COUNTERCLAIM filed by Shenzhen Mengdan Technology Co., Ltd. against Safe&Safety Inc., Shenzhen ZhengMi Technology Co. by Shenzhen Mengdan Technology Co., Ltd.
附件:
1:Exhibit 16 Recall Information
2:Exhibit 15 Invalid Chart
3:Exhibit 14 Invalid Chart
4:Exhibit 13 Invalid Chart
5:Exhibit 12 Prior Art
6:Exhibit 11 Prior Art
7:Exhibit 10 Prior Art
8:Exhibit 9 Prior Art
9:Exhibit 8 Invalid Chart
10:Exhibit 7 Prior Art
11:Exhibit 6 Invalid Chart
12:Exhibit 5 Prior Art
13:Exhibit 4 Invalid Chart
14:Exhibit 3 Prior Art
15:Exhibit 2 Invalid Chart
16:Exhibit 1 Prior Art
07/13/2024 ATTORNEY Appearance for Defendant Shanxi Zhixin Intelligent Technology Co., Ltd by Tao Liu
07/13/2024 ATTORNEY Appearance for Defendant Jiangxi Fingerprint Intelligent Technology Co.,Ltd by Tao Liu
07/10/2024 MINUTE entry before the Honorable John F. Kness: Telephonic motion hearing held 7/10/2024. As discussed on the record, motion by counsel for leave to appear pro hac vice [47] is granted. Oral argument heard. For the reasons stated on the record, Defendants' Emergency Motion to Dissolve the Temporary Restraining Order [39] is granted. The Temporary Restraining Order at Docket [14] is vacated. Plaintiffs' motion [34] is dismissed as moot. Motions [38], [40], [43] and [44] are granted. The oral request by Plaintiffs for issuance of one single summons is granted. The Clerk of Court shall issue summons as to "All Defendants listed on Schedule "A" attached to the Complaint". The parties are directed to file a statement on or before 7/17/2024 regarding a proposed briefing schedule on any motion for preliminary injunction. Mailed notice.
07/10/2024 ATTORNEY Appearance for Defendant The Individuals and Entities Identified on Schedule A to The Complaint by Jeffrey Edward Schiller
07/10/2024 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-22225219.
07/10/2024 REPLY by Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. to response in opposition to motion, [42]
附件:
1:Exhibit 3 Screenshot of YouTube video
2:Exhibit 2 Screeshot of customer review
3:Exhibit 1 Prosecution documents
07/09/2024 MINUTE entry before the Honorable John F. Kness: A telephonic motion hearing on Defendants' motion [39] is set for 7/10/2024 at 1:30 P.M. The parties are to use the following call-in number: 888-684-8852, conference code 3796759. The public and media representatives may have access to the hearing via the same number. Audio recording of the hearing is not permitted; violations of this prohibition may result in sanctions. Participants are directed to keep their device muted when they are not speaking. Mailed notice.
07/09/2024 MOTION by Defendant GUVELI SAFE for extension of time to file answer to Plaintiff's Complaint
07/09/2024 MOTION by Defendant Ninetystar US for extension of time to file answer to Plaintiff's Complaint
07/09/2024 RESPONSE by Safe&Safety Inc., Shenzhen ZhengMi Technology Co.in Opposition to MOTION by Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DI[39]
附件:
1:Exhibit C
2:Exhibit B
3:Exhibit A
07/09/2024 ATTORNEY Appearance for Defendants Ninetystar US, GUVELI SAFE by Pete Scott Wolfgram
07/08/2024 MOTION by Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. for leave to file excess pages
07/08/2024 MOTION by Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. Emergency Motion to Dissolve the Temporary Restraining Order
附件:
1:Exhibit 29 Declaration
2:Exhibit 28 Declaration
3:Exhibit 27 Declaration
4:Exhibit 26 Declaration
5:Exhibit 25 Declaration
6:Exhibit 24 Declaration
7:Exhibit 23 Declaration
8:Exhibit 22 Declaration
9:Exhibit 21 Declaration
10:Exhibit 20 Reviews of Plaintiffs' products
11:Exhibit 19 Recall Information
12:Exhibit 18 screenshots of Plaintiffs' website
13:Exhibit 17 screenshots of Plaintiffs' website
14:Exhibit 16 screenshots of Plaintiffs' Amazon store
15:Exhibit 15 Invalid Chart
16:Exhibit 14 Invalid Chart
17:Exhibit 13 Invalid Chart
18:Exhibit 12 Prior Art
19:Exhibit 11 Prior Art
20:Exhibit 10 Prior Art
21:Exhibit 9 Prior Art
22:Exhibit 8 Invalid Chart
23:Exhibit 7 Prior Art
24:Exhibit 6 Invalid Chart
25:Exhibit 5 Prior Art
26:Exhibit 4 Invalid Chart
27:Exhibit 3 Prior Art
28:Exhibit 2 Invalid Chart
29:Exhibit 1 Prior Art
07/07/2024 MOTION by Attorney Zheng Gong to withdraw as attorney for Safe&Safety Inc., Shenzhen ZhengMi Technology Co. No party information provided
07/07/2024 NOTICE by All Plaintiffs of Attorneys Lien
07/06/2024 ATTORNEY Appearance for Defendants Z ZLJUAN, Karmila, Grimtron's Safety Store, MD MADOATS by Christopher Paul Keleher
07/05/2024 MEMORANDUM by Safe&Safety Inc., Shenzhen ZhengMi Technology Co. in support of extension of time[34] the Temporary Restraining Order
07/05/2024 MOTION by Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. for extension of time Plaintiff's Motion to Extend the Temporary Restraining Order
07/05/2024 ATTORNEY Appearance for Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. by Christina Joanne Blackfor Lesko
07/03/2024 MINUTE entry before the Honorable John F. Kness: Defendants' motion [29] to withdraw emergency motion for compliance [22] is granted. Defendants' emergency motion [22] is dismissed as moot. Mailed notice.
07/03/2024 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD.
07/03/2024 ATTORNEY Appearance for Defendants NINGBO MOYU TRADING CO., LTD., Ningbo Yinzhou Runping Trading Co., Ltd., SHAOXING KEFEI DIGITAL CO., LTD., Shenzhen Yiluo Technology Co., Ltd., YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. by Wei Wang
07/03/2024 MOTION by Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., Ningbo Yinzhou Runping Trading Co., Ltd., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd. to withdraw motion for miscellaneous relief, [22]
07/02/2024 MINUTE entry before the Honorable John F. Kness: Counsel for those Defendants who filed a pending emergency motion [22], along with counsel for Plaintiffs, contacted Court staff today by email to report that Plaintiffs "have now agreed to provide all the unredacted documents requested by Defendants within today's business hours." Counsel also related that Defendants "agree to withdraw their [Emergency] Motion upon receipt of the documents from Plaintiffs." In view of this report, the hearing on the emergency motion that was set for today is stricken. Mailed notice.
07/02/2024 ATTORNEY Appearance for Defendant SHAOXING KEFEI DIGITAL CO., LTD. by Tao Liu
07/02/2024 ATTORNEY Appearance for Defendant NINGBO MOYU TRADING CO., LTD. by Tao Liu
07/02/2024 ATTORNEY Appearance for Defendant YUYAO DINGHUI OPTICAL INSTRUMENT CO., LTD. by Tao Liu
07/02/2024 MINUTE entry before the Honorable John F. Kness: A telephonic motion hearing on Defendants' motion [22] is set for 7/2/2024 at 2:30 P.M. The parties are to use the following call-in number: 888-684-8852, conference code 3796759. The public and media representatives may have access to the hearing via the same number. Audio recording of the hearing is not permitted; violations of this prohibition may result in sanctions. Participants are directed to keep their device muted when they are not speaking. Mailed notice.
07/02/2024 ATTORNEY Appearance for Defendant Dongguan Huaxun Plastic Technology Co., Ltd. by Tao Liu
07/01/2024 MOTION by Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., Ningbo Yinzhou Runping Trading Co., Ltd., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd. Emergency Motion to Require Compliance with Local Rule 26.2, and/or provide all sealed filings without redactions
附件:
1:Exhibit 1
07/01/2024 ATTORNEY Appearance for Defendants Shenzhen Mengdan Technology Co., Ltd., Dongguan Hua'ang Electronics Technology Co., Ltd., Dongguan Huaxun Plastic Technology Co., Ltd., Ningbo Yinzhou Runping Trading Co., Ltd., Shenzhen Yiluo Technology Co., Ltd., Shenzhen Yunli Design Co., Ltd. by Tianyu Ju
07/01/2024 ATTORNEY Appearance for Defendant Shenzhen Yunli Design Co., Ltd. by Wei Wang
07/01/2024 ATTORNEY Appearance for Defendant Dongguan Huaxun Plastic Technology Co., Ltd. by Wei Wang
07/01/2024 ATTORNEY Appearance for Defendant Shenzhen Yiluo Technology Co., Ltd. by Tao Liu
07/01/2024 ATTORNEY Appearance for Defendant Dongguan Hua'ang Electronics Technology Co., Ltd. by Wei Wang
07/01/2024 ATTORNEY Appearance for Defendant Ningbo Yinzhou Runping Trading Co., Ltd. by Tao Liu
06/29/2024 ATTORNEY Appearance for Defendant Shenzhen Mengdan Technology Co., Ltd. by Wei Wang
06/26/2024 Money order BOND in the amount of $ 10,000.00 Rcpt. No: 100007690 posted by Safe&Safety Inc.
06/24/2024 SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 6/24/2024.
06/24/2024 MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for leave to file under seal 3 11, motion for electronic service of process 12, and ex parte motion for a temporary restraining order 10, are granted in part. Plaintiff's submissions (e.g., Dkts. 1012) establish that, were Defendants to learn of these proceedings before the execution of Plaintiff's requested preliminary injunctive relief, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, Plaintiff may for now file under seal the documents identified in the motion to seal and appearing at docket entries 3 and 11. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, Plaintiff's filings support proceeding (for the time being) on an ex parte basis under FRCP 65(b)(1). Specifically, and as noted above, were Defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating Plaintiff's interests in identifying Defendants, stopping Defendants' infringing conduct, and obtaining the equitable accounting that, at this point, Plaintiff states that he may pursue. These facts justify, among other relief, the imposition of a prejudgment asset restraint against Defendants in an amount not to exceed $50,000 per separate account. In addition, the Court finds, at least for now on this limited and one-sided record and without prejudice to revisiting the issue, that it has personal jurisdiction over Defendants because they directly target their business activities toward consumers in the United States, including Illinois. Specifically, Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars, and have sold products using infringing versions of Plaintiff's copyrighted works to residents of Illinois. The evidence presented to the Court also shows that Plaintiff has demonstrated a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to Plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by infringing goods, and there is no countervailing harm to Defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it effectively communicates the pendency of this action to Defendants. As several judges have previously noted, there may be reason to question both the propriety of joining all Defendants in this one action and whether Plaintiff will pursue an accounting (which Plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the Court is persuaded that Plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all Defendants. Expedited discovery is warranted to identify Defendants and to implement the asset freeze. If any Defendant appears and objects, the Court will reconsider the asset freeze and joinder. Enter sealed Temporary Restraining Order. Mailed notice.
05/10/2024 MOTION by Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. for service by publication and Email
05/10/2024 MOTION by Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. to seal document MOTION by Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. for temporary restraining order 10
附件:
1:(Declaration of Mr. Bao ISO Plaintiffs' Motion for TRO)
2:Supplement Memo ISO Plaintiffs' Motion for TRO
05/10/2024 MOTION by Plaintiffs Safe&Safety Inc., Shenzhen ZhengMi Technology Co. for temporary restraining order
05/06/2024 MINUTE entry before the Honorable John F. Kness: Motion by counsel for leave to appear pro hac vice 8 is granted. Mailed notice.
05/02/2024 MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-21926420.
附件:
1:(Exhibit DC Bar Certificate of Good Standing)
2:Exhibit Texas Bar Certificate of Good Standing
04/30/2024 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.
04/30/2024 CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 1).
04/30/2024 MAILED patent report to Patent Trademark Office, Alexandria VA.
附件:
1:(Sealed Exhibit)
04/29/2024 NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by All Plaintiffs
04/29/2024 ATTORNEY Appearance for Plaintiffs SHENZHEN ZHENGMI TECHNOLOGY CO., LTD., Safe&Safety Inc. by Zheng Gong
04/29/2024 CIVIL Cover Sheet
04/29/2024 SEALED MOTION by Plaintiffs SHENZHEN ZHENGMI TECHNOLOGY CO., LTD., Safe&Safety Inc. to File Documents Under Seal
附件:
1:Exhibit 2 to Complaint (Part 3)
2:Exhibit 2 to Complaint (Part 2)
3:Exhibit 2 to Complaint (Part 1)
4:Exhibit 1 to Complaint
5:Appendix Schedule A to Complaint
6:Exhibit Complaint (Sealed)
7:Exhibit 2 to Complaint (Part 4)
8:Exhibit 2 to Complaint (Part 5)
9:Exhibit 2 to Complaint (Part 6)
10:Exhibit 2 to Complaint (Part 7)
11:Exhibit 2 to Complaint (Part 8)
12:(Notice of Filing Plaintiffs' Notice of Claims Involving Patents (Sealed))
04/29/2024 NOTICE by All Plaintiffs of Claims Involving Patents

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