STATUS Report by CAO Group, Inc.

ATTORNEY Appearance for Plaintiff CAO Group, Inc. by Briana Hammons

MINUTE entry before the Honorable Martha M. Pacold: By 7/1/2025, plaintiff should file a status report with an update on the status of the case.

ORDER Signed by the Honorable Martha M. Pacold on 6/20/2025:

MINUTE entry before the Honorable Martha M. Pacold: Plaintiffs' motion for expedited discovery, 27, is granted in part and denied in part. Enter order.

MINUTE entry before the Honorable Martha M. Pacold: The court has received plaintiff's motion for expedited discovery. 27. Plaintiff is instructed to file a proposed order to the court's proposed order inbox (Proposed_Order_Pacold@ilnd.uscourts.gov) by 6/18/2025.

MOTION by Plaintiff CAO Group, Inc. for Expedited Discovery

STATUS Report by CAO Group, Inc.

MINUTE entry before the Honorable Martha M. Pacold: The parties are directed to file a joint status report by 6/10/2025.

附件：

1:(Outline for the initial joint status report)

ORDER Signed by the Honorable Martha M. Pacold on 6/2/2025:

AMENDED complaint by CAO Group, Inc. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A

附件：

1:(Exhibit 3)
2:Exhibit 2
3:Exhibit Schedule A
4:Exhibit 1

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to file instanter a brief in excess of the page limit, 19, is granted.

ORDER Signed by the Honorable Martha M. Pacold on 5/16/2025: Plaintiff is given until 5/29/25 to file an amended complaint. If plaintiff does not file an amended complaint or the court finds that joinder of the defendants named in plaintiff's amended complaint is improper, the court will dismiss all improperly joined defendants without prejudice.

AMENDED complaint by CAO Group, Inc. against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associates Identified on Schedule A (Unredacted Original Complaint)

附件：

1:(Exhibit 3)
2:Exhibit 2
3:Exhibit Schedule A
4:Exhibit 1

MOTION by Plaintiff CAO Group, Inc. for leave to file to File Instanter a Brief in Excess of the Page Limit of Local Rule 7.1

MEMORANDUM by CAO Group, Inc. Addressing the Court's Concerns in Minute Entries 13 and 14

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for electronic service of process, 12, is granted. The court finds that electronic service of process is proper under Fed. R. Civ. P. 4(f)(3). 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. To the extent that the motion requests service of process of any temporary restraining order in this case, service is not necessary because this court has already denied the motion for a TRO. 15.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for a temporary injunction, temporary asset restraint, and expedited discovery, 10, is denied for the reasons stated in the court's prior minute entry. 14.

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion for leave to file under seal, [4], is denied. Plaintiff seeks leave to file under seal so that plaintiff may obtain a temporary restraining order freezing the defendants' assets before revealing the defendants' identities. Id. "The Supreme Court has made clear that courts lack the power to issue an asset freeze at the beginning of a case, unless that party is seeking equitable monetary relief." Zorro Productions, Inc. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, No. 23-cv-5761, 2023 WL 8807254, at *4 (N.D. Ill., Dec. 20, 2023) (citing Grupo Mexicano de Desarrollo S.A. v. All. Bond Fund, Inc., 527 U.S. 308 (1999)); see also Shenzhen Yihong Lighting Co., Ltd. v. The Partnerships and Unincorporated Associations Identified on Schedule A, No. 23-cv-1560, at Dkt. 15 (N.D. Ill. Nov. 22, 2023). Indeed, "[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." Id. (second alteration in original) (quoting Banister v. Firestone, No. 17-cv-8940, 2018 WL 4224444, at *9 (N.D. Ill. Sept. 5, 2018)). In Schedule A cases, plaintiffs often initially demand equitable relief in the form of an accounting of profits, but after obtaining a temporary asset freeze, plaintiffs uniformly shift their focus to demanding statutory damages. Id. at *3-4. In substance, then, if not in form, Schedule A plaintiffs seek prejudgment asset restraints to establish a fund from which money damages may be awarded. So, despite the demand in plaintiff's complaint that it be awarded defendant's profits, the court is not persuaded that plaintiff will actually seek or obtain such equitable relief-as opposed to statutory damages-in this case. See Zorro, 2023 WL 8807254, at *3-4. Thus, even if plaintiff's initial demand for an accounting of profits could provide this court with the power to issue a prejudgment asset freeze, see Grupo Mexicano, 527 U.S. at 333; Banister, 2018 WL 4224444, at *9, the court is not persuaded that such a freeze is warranted. Plaintiff's motion for leave to file under seal, [], is therefore denied. Plaintiff's sealed documents, [5], [6], are stricken. If plaintiff wishes to proceed with this case, plaintiff must file its complaint and any exhibits publicly on the docket by 4/28/2025.

MOTION by Plaintiff CAO Group, Inc. for Alternative Service pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff CAO Group, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

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. (qrtr,)

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Daniel P. McLaughlin. Case assignment: Random assignment. (Civil Category 1). (qrtr,)

ATTORNEY Appearance for Plaintiff CAO Group, Inc. by Sameeul Haque

ATTORNEY Appearance for Plaintiff CAO Group, Inc. by Nicholas S. Lee

Notice of Affiliates Pursuant to LR 3.2 by CAO Group, Inc.

SEALED DOCUMENT by Plaintiff CAO Group, Inc. Notice of Claims

SEALED DOCUMENT by Plaintiff CAO Group, Inc. Sealed Complaint and Exhibits

附件：

1:(Exhibit 3)
2:Exhibit 1
3:Exhibit 2
4:Exhibit Schedule A

MOTION by Plaintiff CAO Group, Inc. for leave to file Certain Documents Under Seal

Notice of Claims by CAO Group, Inc. (Redacted)

CIVIL Cover Sheet

COMPLAINT (Redacted) filed by CAO Group, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-23347797.

附件：

1:(Exhibit 3 (Redacted))
2:Exhibit 2 (Redacted)
3:Exhibit 1 (Redacted)
4:Exhibit Schedule A (Redacted)