RESPONSE by Adoo Rablein Opposition to MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for preliminary injunction [35]

附件：

1:Exhibit 1
2:Declaration of Linna Xu
3:Declaration of Dr. Luo Xiaohua

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Adoo Rable, MOTION by Defendant Adoo Rablefor more definite statement

STATUS Report JOINT by Adoo Rable

ORDER Signed by the Honorable Sunil R. Harjani on 6/13/2025. Mailed notice

[CORRECTED] MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's Motion [35] for Entry of a Preliminary Injunction is entered and continued. By agreement of the parties, the injunctive relief previously granted in the TRO shall remain in place until the Motion is fully brief and decided by this Court, with the exception of the asset restraint previously entered. There shall be no restraint of Defendant's assets until further order of the Court. The Order entered today shall expire upon the granting or denying of Plaintiff's Motion for Entry of a Preliminary Injunction [35]. Per the parties' request, documents [2], [12], and [16] shall remain sealed. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Videoconference hearing held. Motion by Defendant Adoo Rable to set briefing schedule [40-1] is granted. Defendant's Adoo Rable's response brief to Plaintiff's motion for preliminary injunction [35] is due by 6/24/2025 and Plaintiff shall reply by 7/15/2025. For the reasons stated on the record, Defendant's motion to unseal [40-2] is granted as modified on the record. The Clerk's office is directed to unseal dkts. [12], [16], [23], and [27]. Docket entry no. [2] shall remain under seal by agreement of the parties. Defendant's motion to strike asset restraint [40-3] is moot as the temporary restraining order has expired, but the parties have agreed to a preliminary injunction order that will continue the terms of the TRO, without the asset restraint, that will govern until the Court rules substantively on Plaintiff's motion for a preliminary injunction order, and to allow time for the parties to fully brief the issue. By the close of business 6/13/2025, Defendant shall submit a revised proposed order via email to Proposed_Order_Harjani@ilnd.uscourts.gov. The parties are also encouraged to settle and to that end, counsel are ordered to meet and confer by video or telephone by 6/20/25 and to file a joint status report by 6/27/25 on the result of their discussions and whether there is potential for settlement. Mailed notice

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Adoo Rable

MINUTE entry before the Honorable Sunil R. Harjani:Defendant's Motion to Set Briefing Schedule, Unseal Documents, and Strike Asset Restraint [40] is set for 6/12/2025 at 10:00 a.m. via videoconference. Details shall follow. The tentative preliminary injunction hearing set for 6/10/2025 is stricken.

MOTION by Defendant Adoo Rable to set a briefing schedule re: [Dkt. 35], MOTION by Defendant Adoo Rable to unseal document re: [Dkts. 2, 12, 16, 23, 27], MOTION by Defendant Adoo Rable to strike asset restraint

CERTIFICATE of Service by Allen Justin Poplin on behalf of Jiangmen Pengjiang Tianli New Tech Co., Ltd. regarding terminate hearings, set/reset hearings, [37] (Poplin, Allen Justin)

ATTORNEY Appearance for Defendant Adoo Rable by Adam Edward Urbanczyk

MINUTE entry before the Honorable Sunil R. Harjani: Before the Court is plaintiff's motion [35] for entry of a preliminary injunction. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by 6/8/2025." If no objections are filed by that date, the Court will consider the motion unopposed. The Court will also rule on the papers unless a hearing is requested by 6/8/2025. A hearing, to be conducted via teleconferencing, may be requested by filing a Request for Hearing. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. Status hearing set for 6/10/2025 at 9:15 a.m. is converted to a tentative preliminary injunction hearing. Mailed notice

CERTIFICATE of Service by Allen Justin Poplin on behalf of Jiangmen Pengjiang Tianli New Tech Co., Ltd. regarding MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for preliminary injunction [35] (Poplin, Allen Justin)

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for preliminary injunction (Poplin, Allen Justin)

SUMMONS Returned Executed by Jiangmen Pengjiang Tianli New Tech Co., Ltd. as to The Partnerships And Unincorporated Associations Identified On Schedule A, on 6/2/2025, answer due 6/23/2025. (Poplin, Allen Justin)

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and all other Defendants identified in the Complaint

SUMMONS Submitted (Court Participant) for defendant(s) The Partnerships and all other Defendants identified in the Complaint by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. (Poplin, Allen Justin)

Civil BOND in the amount of $ 10,000.00, CASHIER'S CHECK, receipt no. 100020150 posted by Jiangmen Pengjiang Tianli New Tech Co., Ltd.

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's Ex Parte Motion to Extend the Temporary Restraining Order [29] is granted. For the reasons stated in Plaintiff's Memorandum [30], the Court finds good cause to extend the temporary restraining order an additional 14 days to 6/10/2025. Plaintiff shall file a preliminary injunction motion if appropriate no later than 6/3/2025. Telephone status hearing set for 5/27/2025 is stricken and reset to 6/10/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

MEMORANDUM by Jiangmen Pengjiang Tianli New Tech Co., Ltd. in support of motion for temporary restraining order[29]

附件：

1:Declaration Poplin declaration

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for temporary restraining order extension (Poplin, Allen Justin)

Registry Deposit Information Form by Jiangmen Pengjiang Tianli New Tech Co., Ltd.

Sealed Temporary Restraining Order Signed by the Honorable Sunil R. Harjani on 5/13/2025. Mailed notice

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motion for leave to file under seal [24], ex parte motion for a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery [21], and motion for electronic service of process [20] are granted. Plaintiff's submissions 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 file under seal the documents identified in the motion to seal. 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 on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. Further, the evidence submitted by plaintiff shows 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 counterfeit products, 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. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order at 3:45 p.m. on 5/13/2025. Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) if appropriate no later than 5/20/2025. Telephone status hearing is set for 5/27/2025 at 9:15 a.m. The call-in number is (855) 244-8681 and the access code is 172 628 1276##. Attorneys of record may not use speakerphones during the status hearing. Members of the public and media will be able to call in to listen to this hearing but will be placed on mute. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Mailed notice

STATUS Report by Jiangmen Pengjiang Tianli New Tech Co., Ltd. (Poplin, Allen Justin)

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. to seal document sealed document[23] (Poplin, Allen Justin)

SEALED DOCUMENT by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. [22-1] (Poplin, Allen Justin)

MEMORANDUM by Jiangmen Pengjiang Tianli New Tech Co., Ltd. in support of motion for temporary restraining order[21]

附件：

1:Exhibit 1

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for temporary restraining order (Poplin, Allen Justin)

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd.Electronic Service of Process (Poplin, Allen Justin)

MINUTE entry before the Honorable Sunil R. Harjani: By 5/9/2025, Plaintiff shall file a status report with an update on the case. Mailed notice

ORDER Signed by the Honorable Sunil R. Harjani on 4/21/2025: The Court has reviewed the plaintiff's memorandum on joinder [15]. For the reasons stated in the attached Order, the Court determines, within its discretion, that plaintiff has failed to satisfy its burden to show that joinder of 13 defendants is proper in this matter under Fed. R. Civ. P. 20(a)(2). Accordingly, the Court dismisses defendant Nos. 3-13 without prejudice. If plaintiff files a new action against defendants Nos. 3-13, plaintiff shall indicate on the Civil Cover Sheet that the filed case is related to this matter. See Local Rule 40.3(b)(2). Plaintiff's motion for electronic service of process [9] and motion for temporary restraining order [10] are denied without prejudice. Plaintiff may refile its motions consistent with this Order. Plaintiff's motions to file under seal [4, 13, 17] are granted. Mailed notice

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. to seal document sealed document[16] (Poplin, Allen Justin)

SEALED DOCUMENT by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. Exhibit 1: Declaration of Zhaoxian Zhen (Poplin, Allen Justin)

RESPONSE by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. to text entry, [14]

附件：

1:Exhibit 1: Declaration of Zhaoxian Zhen

MINUTE entry before the Honorable Sunil R. Harjani: Plaintiff's motions for leave to file under seal [4, 13], plaintiff's motion for electronic service of process [9], and plaintiff's motion for temporary restraining order [10] are entered and continued. Upon review of the complaint and the TRO submissions, the Court sua sponte raises the proprietary of joinder of 13 defendants in this case. See, e.g., Estee Lauder Cosmetics Ltd. v. Schedule A, 334 F.R.D. 182 (N.D. Ill. 2020). By 4/7/2025, plaintiff shall file a supplemental memorandum addressing the propriety of joinder in light of the principles described in Estee Lauder. In the alternative, plaintiff has leave to file an amended complaint with a single defendant or a smaller subset of defendants along with its memorandum explaining specifically why each defendant is properly joined to all of the others. Estee Lauder, 334 F.R.D. at 189. Mailed notice

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. to seal document sealed document[12] (Poplin, Allen Justin)

SEALED DOCUMENT by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. Exhibit 1 (Poplin, Allen Justin)

MEMORANDUM by Jiangmen Pengjiang Tianli New Tech Co., Ltd. in support of motion for temporary restraining order[10]

附件：

1:Exhibit 1

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. for temporary restraining order (Poplin, Allen Justin)

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd.Electronic Service of Process (Poplin, Allen Justin)

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 Jiangmen Pengjiang Tianli New Tech Co., Ltd. by Wangxue Deng

Notice of Patent Claims by Jiangmen Pengjiang Tianli New Tech Co., Ltd. (Poplin, Allen Justin)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Jiangmen Pengjiang Tianli New Tech Co., Ltd. (Poplin, Allen Justin)

ATTORNEY Appearance for Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. by Allen Justin Poplin (Poplin, Allen Justin)

MOTION by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. to seal document sealed document[2] (Poplin, Allen Justin)

CIVIL Cover Sheet (Poplin, Allen Justin)

SEALED DOCUMENT by Plaintiff Jiangmen Pengjiang Tianli New Tech Co., Ltd. Schedule A (Poplin, Allen Justin)

COMPLAINT filed by Jiangmen Pengjiang Tianli New Tech Co., Ltd.; Jury Demand. Filing fee $ 405, receipt number AILNDC-23273471.

附件：

1:Appendix Schedule A
2:Exhibit 1