DECLARATION of Konrad Sherinian regarding motion for miscellaneous relief 26

MEMORANDUM by Sigmaxgo LLC in support of motion for miscellaneous relief 26

MOTION by Plaintiff Sigmaxgo LLCService by E-Mail and Publication on a Webite

DECLARATION of Depeng Bi regarding motion for discovery 24

MOTION by Plaintiff Sigmaxgo LLC for discovery Expedited Discovery

Exh 1 to Dec of Feifei Ju by Sigmaxgo LLC

Schedule A to Complaint by Sigmaxgo LLC

Exhibit 1 to Complaint by Sigmaxgo LLC

MINUTE entry before the Honorable Martha M. Pacold: Plaintiff's motion to seal, 17, is denied. Plaintiff's sealed documents, 2, 3, 13, are stricken. The motion asks for the documents to be filed under seal to allow for ex parte relief. As explained in the court's previous minute entry, 18, however, the court finds that ex parte relief is not warranted. Accordingly, there is no basis to allow the documents to be filed under seal. If plaintiff wishes to proceed with this case, it should file its documents publicly on the docket by 9/2/2025.

MINUTE entry before the Honorable Martha M. Pacold: By 9/3/2025, plaintiff is ordered to show cause why this case should not be dismissed or severed for improper joinder. Plaintiff is advised of the following: First, "[o]n motion or on its own, the court may at any time, on just terms, add or drop a party." Fed. R. Civ. P. 21(a). Second, sua sponte review of the propriety of joinder in Schedule A cases is a regular practice of courts in this district because plaintiffs "routinely file these multi-defendant cases. using cookie-cutter complaints that allege in a conclusory manner that 'on information and belief' each infringing defendant is inter-connected with the others." Viking Arm AS v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", No. 24-cv-1566, 2024 WL 2953105, at *1 (N.D. Ill. June 6, 2024). Third, "[c]ourts generally find that claims against different defendants arose out of the same transaction or occurrence only if there is a logical relationship between the separate causes of action." Estee Lauder Cosms. Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", 334 F.R.D. 182, 185 (N.D. Ill. 2020) (citations and internal quotation marks omitted). Fourth, courts have held that "to be part of the same transaction requires shared, overlapping facts that give rise to each cause of action, and not just distinct, albeit coincidentally identical, facts." Id. (quoting In re EMC Corp., 677 F.3d 1351, 1359 (Fed. Cir. 2012)). Fifth, courts have held that the allegation that multiple defendants have infringed on the same copyright or trademark in the same way "does not create the substantial evidentiary overlap required to find a similar transaction or occurrence." Roadget Bus. Pte. Ltd. v. Schedule A Defs., No. 23-cv-17036, 2024 WL 1858592, at *6 (N.D. Ill. Apr. 29, 2024) (collecting cases). Finally, courts have held that the allegation that defendants "share unique identifiers, such as design elements and similarities of the unauthorized products offered for sale," is not sufficient to establish joinder. Ilustrata Servicos Design, Ltd. v. P'ships & Unincorporated Ass'ns Identified on Schedule "A", No. 21-cv-05993, 2021 WL 5396690, at *2 (N.D. Ill. Nov. 18, 2021); Art Ask Agency v. Individuals, Corps., Ltd. Liab. Cos., P'ships, & Unincorporated Ass'ns Identified on Schedule "A", No. 21-cv-06197, 2021 WL 5493226, at *2 (N.D. Ill. Nov. 23, 2021).

MINUTE entry before the Honorable Martha M. Pacold: (1) Plaintiff's motion for leave to file excess pages, 14, is granted. (2) Plaintiff's motion for temporary restraining order, 8, is denied. (a) The motion seeks an ex parte TRO, but plaintiff's attorney has not "certifie[d] in writing any efforts made to give notice." Fed. R. Civ. P. 65(b)(1)(B). (b) Plaintiff has not adequately established personal jurisdiction. "For a TRO. to be valid, the issuing Court must have personal jurisdiction over the defendants." Am. Bridal & Prom Indus. Ass'n, Inc. v. The P'ships & Unincorporated Ass'ns Identified on Schedule A, 192 F. Supp. 3d 924, 930 (N.D. Ill. 2016). The Seventh Circuit has, in some cases, found the existence of specific personal jurisdiction in trademark, copyright, and patent infringement suits against online retailers, but only when the defendant has shipped the allegedly infringing products to the forum state. See, e.g., NBA Props., Inc. v. HANWJH, 46 F.4th 614, 622-23 (7th Cir. 2022); Curry v. Revolution Lab'ys, LLC, 949 F.3d 385, 399 (7th Cir. 2020); Illinois v. Hemi Group, LLC, 622 F.3d 754, 758 (7th Cir. 2010). Absent fulfillment and shipment of an order into the forum state, the operation of an "interactive" online storefront is insufficient to establish personal jurisdiction. See Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796, 803 (7th Cir. 2014) ("Having an interactive website. should not open a defendant up to personal jurisdiction in every spot on the planet where that interactive website is accessible."). Here, the complaint alleges that "[e]ach of the Defendants has targeted Illinois residents by operating online stores that offer shipping to the United States, including Illinois, [and] accept payment in U.S. dollars." 1 para. 2; see also id. para. 25. However, "displaying products online that are shippable to Illinois amounts to nothing more than maintaining an interactive website that is accessible in Illinois. That alone cannot confer personal jurisdiction." Rubik's Brand, Ltd. v. P'ships and Unincorporated Ass'ns Identified in Schedule A, No. 20-cv-5338, 2021 WL 825668, at *3 (N.D. Ill. Mar. 4, 2021) ("The maintenance of an interactive website, without more, is insufficient to vest a court with personal jurisdiction."). Further, the complaint alleges that defendants "on information and belief, have sold products bearing infringing versions of Plaintiff's federally registered copyrighted works to residents of Illinois." 1 para. 2; see id. para. 25-26. However, "conclusory allegations stated only upon 'information and belief,' are insufficient to establish that the court has personal jurisdiction over a defendant." Cagan v. Gadman, CV 08-3710 (SJF) (ARL), 2009 WL 10712634, at *4 (E.D.N.Y. July 6, 2009) (citation omitted). Accordingly, plaintiff has not adequately established that the court has personal jurisdiction over defendants.

MOTION by Plaintiff Sigmaxgo LLC to seal document sealed document 13, sealed document 3, sealed document 2

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Martha M. Pacold for all further proceedings pursuant to Local Rule 28:294(b). Mailed notice.

附件：

1:(Request for Reassignment) (bi,)

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. Mailed notice.

MOTION by Plaintiff Sigmaxgo LLC for leave to file excess pages

SEALED DOCUMENT by Plaintiff Sigmaxgo LLC Exh 1 to Dec Feifei Ju (stores 1-6)

附件：

1:Exhibit Stores 12-16
2:Exhibit Stores 17-22
3:(Exhibit Stores 23-28)
4:Exhibit Stores 7-11

DECLARATION of Feifei Ju regarding motion for temporary restraining order 8

DECLARATION of Depeng Bi regarding complaint, 1

附件：

1:Exhibit Exh 1 - Web Page of Global Shield
2:(Exhibit Exh 2 - Web Page of 123TRO)

DECLARATION of Konrad Sherinian regarding motion for temporary restraining order 8

附件：

1:Exhibit Exh. 1 - Intellectual Property Rights Seizure Statistics
2:Exhibit Exh. 2 - The Economic Impacts of Counterfeiting and Piracy
3:Exhibit Exh 3 - Hague Convention
4:(Exhibit Exh 4 - Civil Pro of PRC)

MEMORANDUM by Sigmaxgo LLC in support of motion for temporary restraining order 8

MOTION by Plaintiff Sigmaxgo LLC for temporary restraining order

MAILED copyright report to Registrar, Washington DC

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.

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

ATTORNEY Appearance for Plaintiff SIGMAXGO LLC by Depeng Bi

ATTORNEY Appearance for Plaintiff SIGMAXGO LLC by Konrad Val Sherinian

CIVIL Cover Sheet

SEALED DOCUMENT by Plaintiff SIGMAXGO LLC Exh 1 to Complaint - IP Asserted

SEALED DOCUMENT by Plaintiff SIGMAXGO LLC Sealed Schedule A to Complaint

COMPLAINT filed by SIGMAXGO LLC; Filing fee $ 405, receipt number AILNDC-23873129.

附件：

1:Exhibit Exh 3 - Fighting China's Counterfeits
2:Exhibit Exh 2 - Combating Trafficking in Counterfeit and Pirated Goods
3:Exhibit Exh 1 - Copyrights Asserted - Public
4:(Exhibit Exh 4 - Intellectual Property Rights Seizure Statistics)