FULL SATISFACTION of Judgment regarding order, entered judgment 49 in the amount of $5,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order, entered judgment 49 in the amount of $5,000 as to certain defendant

CITATION to Discover Assets issued as to Amazon.com, Inc. and PayPal, Inc. (Third Parties)

PERMANENT INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 10/4/2022. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Steven C. Seeger on 10/4/2022. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for entry of default and default judgment (Dckt. No. 39) is hereby granted as follows. The responses to the complaint are overdue. The Court enters default against the remaining defendants on Schedule A under Rule 55(a), and enters default judgment under Rule 55(b). Several months have passed since Plaintiff filed the motion, and Defendants did not respond, despite receiving service. (Dckt. No. 36, at 3 of 3]) Defendants have waived any response. In its brief, Plaintiff requested an order "transferring all assets in Defaulting Defendants' financial accounts." The Court declines to award that relief. Plaintiff seeks statutory damages, not monetary equitable relief (like an accounting of profits). The Court will not compel the transfer of funds frozen through this Court's equitable powers given that Plaintiff is not seeking or obtaining monetary equitable relief. The asset freeze imposed by this Court's temporary restraining order (Dckt. No. 27) has expired. Plaintiff shall expressly notify any third party holding frozen funds that the asset freeze is no longer in place, and shall provide a copy of this Order within one week. Plaintiff can enforce the judgment as provided in the Federal Rules. Final Judgment Order to follow. Permanent Injunction Order to follow. The motion for a preliminary injunction (Dckt. No. 32) is denied as moot in light of the entry of the permanent injunction. The case is closed. Civil case terminated. Mailed notice

MINUTE entry before the Honorable Steven C. Seeger: At plaintiff's request, the deadline to file a joint initial status report is extended to December 16, 2022. Mailed notice.

Statement Regarding Asset Freeze STATEMENT by Converse Inc. per 45

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for a preliminary injunction (Dckt. No. 32). The motion includes a request for an asset freeze. By August 19, 2022, Plaintiff must file a statement and point to the statutory provision that gives this Court the power to impose an asset freeze at the outset of the case. If Plaintiff cannot point to a specific statutory provision, then Plaintiff must address how its request for an asset freeze is consistent with Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999). In its brief in support of a TRO, Plaintiff argues that "[c]ourts have the inherent authority to issue a prejudgment asset restraint when plaintiff's complaint seeks relief in equity." See Mem., at 12. In Grupo Mexicano, the Supreme Court held that a district court has "no authority to issue a preliminary injunction preventing [a defendant] from disposing of their assets pending adjudication of [plaintiff's] contract claim for money damages." Id. at 333. The Supreme Court adhered to the long-standing rule that "a judgment establishing the debt was necessary before a court of equity would interfere with the debtor's use of his property." Id. at 321. "However, the [Grupo] [C]ourt specifically noted that a restraint on assets was still proper if a suit sought equitable relief." See CSC Holdings, Inc. v. Redisi, 309 F.3d 988, 996 (7th Cir. 2002) (citing Grupo, 527 U.S. at 333; Deckert v. Independence Shares Corp., 311 U.S. 282, 288 (1940)). "[A]s a general matter [] prejudgment asset restraints are not proper simply to establish a fund from which a later award of money damages can be satisfied." See Banister v. Firestone, 2018 WL 4224444, at *9 (N.D. Ill. 2018). An equitable restraint at the outset of the case might be doable if Plaintiff obtained equitable monetary relief at the end of the day, like an accounting of profits. See Deckers Outdoor Corp. v. Unincorporated Associations Identified on Schedule A, 2013 WL 12314399 (N.D. Ill. 2013). But as a practical matter, in Schedule A cases, that recovery almost never happens, if at all. Instead, plaintiffs rush into court, seek and obtain an asset freeze, obtain a default judgment, and then ask district courts to unfreeze the money and award statutory damages, not equitable relief. In that scenario, it is not clear to this Court that it would be appropriate to use any frozen funds for any recovery of statutory damages, because statutory damages are a remedy at law, not a remedy in equity. If Plaintiff believes that it is appropriate for this Court to freeze funds at the outset of the case, and then use those funds to recover statutory damages (not equitable monetary relief) at the end of the case, then Plaintiff must explain why. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: At plaintiff's request, the deadline to file a joint initial status report is extended to September 30, 2022. Mailed notice.

NOTICE of Voluntary Dismissal by Converse Inc. as to certain defendants

MINUTE entry before the Honorable Steven C. Seeger: At plaintiff's request, the deadline to file a joint initial status report is extended to July 17, 2022. Mailed notice.

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

附件：

1:(Exhibit 1)

MEMORANDUM by Converse Inc. in support of motion for entry of default, motion for default judgment 39

附件：

1:(Exhibit 1)

MOTION by Plaintiff Converse Inc. for entry of default as to all Defendants, MOTION by Plaintiff Converse Inc. for default judgment as to all Defendants

附件：

1:(Exhibit A)

NOTICE of Voluntary Dismissal by Converse Inc. as to a Certain Defendant

NOTICE of Voluntary Dismissal by Converse Inc. as to a Certain Defendant

ATTORNEY Appearance for Plaintiff Converse Inc. by Marcella Deshonda Slay

SUMMONS Returned Executed by Converse Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 5/3/2022, answer due 5/24/2022.

附件：

1:Declaration of Rachel S. Miller
2:(Exhibit A)

ATTORNEY Appearance for Plaintiff Converse Inc. by Rachel S Miller

DECLARATION of Jake M. Christensen regarding motion for preliminary injunction, extension of time[32]

附件：

1:Exhibit 1

MOTION by Plaintiff Converse Inc. for preliminary injunction, MOTION by Plaintiff Converse Inc. for extension of time of Temporary Restraining Order

附件：

1:Exhibit A

MINUTE entry before the Honorable Steven C. Seeger: At plaintiff's request, the deadline to file a joint initial status report is extended to June 17, 2022. Mailed notice.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for extension of the TRO (Dckt. No. 29) is hereby granted. The Court extends the TRO until 5:00 p.m. on May 6, 2022. Mailed notice

MOTION by Plaintiff Converse Inc. for extension of time of Temporary Restraining Order

附件：

1:Declaration of Jake M. Christensen

SURETY BOND in the amount of $152,000.00 posted by plaintiff Converse Inc. (Document not scanned)

SEALED TEMPORARY Restraining Order Signed by the Honorable Steven C. Seeger on 4/8/2022. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. [3]) is hereby granted. Plaintiff's motion for electronic service of process (Dckt. No. [19]) is hereby granted. Plaintiff's motion for a temporary restraining order (Dckt. No. [14]) is hereby granted. Temporary Restraining Order to follow. Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: The motion to withdraw as counsel (Dckt. No. 24) is granted. Attorney RiKaleigh C. Johnson is terminated as counsel of record. Mailed notice.

MOTION by Attorney RiKaleigh C. Johnson to withdraw as attorney for Converse Inc. No party information provided

REFUND PROCESSED to Attorney Justin Gaudio re COMPLAINT 1 filed by Converse Inc. Filing fee $ 402, receipt number 0752-19103639.

REQUEST for Clerk of Court to refund filing fee in the amount of $402.00, receipt no. 075219103639, regarding complaint[1] Converse Inc. v. The Partnerships, et al.

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[20]

附件：

1:Exhibit 1
2:Exhibit 2

MEMORANDUM by Converse Inc. in support of motion for miscellaneous relief[19]

MOTION by Plaintiff Converse Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

SEALED EXHIBIT by Plaintiff Converse Inc. Exhibit 3 - Parts 1-2 regarding declaration[17]

DECLARATION of Joe Pallett regarding memorandum in support of motion[15]

附件：

1:Exhibit 1
2:Exhibit 2

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[15]

附件：

1:Exhibit 1
2:Exhibit 2
3:Exhibit 3
4:Exhibit 4

MEMORANDUM by Converse Inc. in support of motion for temporary restraining order[14]

MOTION by Plaintiff Converse Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by April 18, 2022. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MAILED trademark report to Patent Trademark Office, Alexandria VA

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.

ATTORNEY Appearance for Plaintiff Converse Inc. by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff Converse Inc. by RiKaleigh C. Johnson

ATTORNEY Appearance for Plaintiff Converse Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff Converse Inc. by Justin R. Gaudio

Notice of Claims Involving Trademarks by Converse Inc.

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Converse Inc.

CIVIL Cover Sheet

MOTION by Plaintiff Converse Inc. for leave to file under seal

SEALED EXHIBIT by Plaintiff Converse Inc. Schedule A regarding complaint[1]

COMPLAINT filed by Converse Inc.; Filing fee $ 402, receipt number 0752-19103689.

附件：

1:Exhibit 1
2:Exhibit 2
3:Exhibit 3
4:Exhibit 4