ABC Corporation I et al v. The Partnership and Unincorporated Associations Identified on Schedule "A"
| ABC Corporation I and ABC Corporation II |
| The Partnership and Unincorporated Associations Identified on Schedule "A", GYROOR US, TOMOLOO-US, TOMOLOO Franchise, Tomoloo DX, Tomoloo INT, EVERCROSS, XPRITINC, Tomoloo TC, TOMOLOO INE, Tomoloo Flagship and Tomoloo Official |
| eBay, Inc. |
| 1:2020cv04806 |
| August 17, 2020 |
| US District Court for the Northern District of Illinois |
| Thomas M Durkin |
| Steven C Seeger |
| Patent |
| 35 U.S.C. § 271 |
| Plaintiff |
Docket Report
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This docket was last retrieved on January 12, 2024. A more recent docket listing may be available from PACER.
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Filing 167
MINUTE entry before the Honorable Thomas M. Durkin: The motion hearing scheduled for 1/22/2021 is vacated. Pursuant to the stipulation #166 , the motion for default and default judgment #155 is withdrawn without prejudice. Defendant Tomoloo is to file their motion to dismiss or responsive pleading by 2/10/2021. Plaintiffs are to file their response to Defendant Gyroor's pending motion to dismiss #165 and any motion to dismiss filed by Defendant Tomoloo by 3/3/2021. Defendants Gyroor and Tomoloo will file their replies to Plaintiffs' response by 3/10/2021. A telephone status hearing is set for 4/12/2021 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice. (ecw, )
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Filing 166
STIPULATION regarding motion to dismiss #165 , motion for default judgment,, #155 - withdrawing Plaintiffs' Motion for Default without prejudice, and setting briefing schedule on Defendant Tomoloo's anticipated Motion to Dismiss and Defedant Gyroor's pending Motion to Dismiss (Binns, Christopher)
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Filing 165
MOTION by Defendant GYROOR US to dismiss Plaintiff's Third Amended Complaint with Prejudice (Attachments: #1 Declaration Declaration of Vegh, #2 Declaration Declaration of Rongqing)(McKinley, Danielle)
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Filing 164
ATTORNEY Appearance for Defendant Tomoloo INT by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 163
ATTORNEY Appearance for Defendant Tomoloo DX by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 162
ATTORNEY Appearance for Defendant Tomoloo TC by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 161
ATTORNEY Appearance for Defendant Tomoloo Flagship by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 160
ATTORNEY Appearance for Defendant TOMOLOO-US by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 159
ATTORNEY Appearance for Defendant TOMOLOO Franchise by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 158
ATTORNEY Appearance for Defendant TOMOLOO INE by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 157
ATTORNEY Appearance for Defendant Tomoloo Official by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 156
MINUTE entry before the Honorable Thomas M. Durkin: Telephone hearing as to the motion for default judgment #155 is set for 1/22/2021 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice. (ecw, )
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Filing 155
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for default judgment as to TOMOLOO Defendants (Attachments: #1 Memorandum of Law in Support of Plaintiffs' Motion for Entry of Default and Default Judgment Against TOMOLOO Defendants, #2 Exhibit A - Defaulting Defendants List, #3 Exhibit B - Declaration of Christopher Binns, #4 Ex. 1 - Expedited Discovery Requests, #5 Ex. 2 - Requests for Admission, #6 Ex. 3 - Unpublished Decisions, #7 Exhibit C - Declaration of Yijun Lui)(Kelly, Adam)
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Filing 154
MINUTE entry before the Honorable Thomas M. Durkin: Motion to appear pro hac vice #153 is granted. Attorney Stephen Z. Vegh for GYROOR US added. Mailed notice. (ecw, )
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Filing 153
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17817800. (Vegh, Stephen)
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Filing 152
ATTORNEY Appearance for Defendant GYROOR US by Danielle Sylvia McKinley (McKinley, Danielle)
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Filing 151
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II - Certificate of Service re: Third Amended Complaint #101 and Preliminary Injunction Order #147 (Binns, Christopher)
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Filing 150
CERTIFICATE of Service by Plaintiffs ABC Corporation I, ABC Corporation II regarding sealed document,, #101 , SEALED Order #147 - Certificate of Service re: Third Amended Complaint #101 and Preliminary Injunction Order #147 (Binns, Christopher)
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Filing 149
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II - Certificate of Service re: Third Amended Complaint #101 and Preliminary Injunction Order #147 (Binns, Christopher)
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Filing 148
CONSENT JUDGMENT: Motion to approve consent judgment #146 is granted. Signed by the Honorable Thomas M. Durkin on 12/28/2020. Mailed notice. (ecw, )
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Filing 147
SEALED ORDER. Signed by the Honorable Thomas M. Durkin on 12/23/2020. Mailed notice. (ecw, )
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Filing 146
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to approve consent judgment re: Plaintiffs Hangzhou Chic Intelligent Technology Co. and Unicorn Global, Inc. and Defendant EVERCROSS (Kelly, Adam)
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Filing 145
MINUTE entry before the Honorable Thomas M. Durkin: Telephone conference held on 12/23/2020. For the reasons stated on the record, Third Party Plaintiff eBay, Inc.'s Motion for Relief from the Preliminary Injunction Order #128 , #129 is granted in part and denied in part. A revised proposed preliminary injunction order is to be submitted today with the changes outlined during the telephone conference. eBay is to comply with the new order by 12/28/2020, or within five days of the date of entry of the order. Mailed notice. (ecw, )
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Filing 144
MINUTE entry before the Honorable Thomas M. Durkin: The telephone conference set for 12/22/2020 at 2:00 p.m. is reset for 12/23/2020 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 143
REPLY by eBay, Inc. to memorandum in opposition to motion, #133 (Redacted Version) (Cederoth, Richard)
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Filing 142
SEALED DOCUMENT by ThirdParty Plaintiff eBay, Inc. Declaration of Rebekah Long In Support Of Reply In Support Of Motion For Relief From The Preliminary Injunction (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Cederoth, Richard)
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Filing 141
MINUTE entry before the Honorable Thomas M. Durkin: Motion to seal #137 is granted. Mailed notice. (ecw, )
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Filing 140
SEALED DOCUMENT by ThirdParty Plaintiff eBay, Inc. Declaration Of Paul J. Rogerson In Support Of Reply In Support Of Motion For Relief From The Preliminary Injunction (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Cederoth, Richard)
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Filing 139
SEALED DOCUMENT by ThirdParty Plaintiff eBay, Inc. Reply In Support Of Motion For Relief From The Preliminary Injunction Order (Cederoth, Richard)
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Filing 138
NOTICE of Motion by Richard A. Cederoth for presentment of motion to seal #137 before Honorable Thomas M. Durkin on 12/24/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 137
MOTION by ThirdParty Plaintiff eBay, Inc. to seal (Cederoth, Richard)
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Filing 136
MINUTE entry before the Honorable Thomas M. Durkin: Motion to seal document #135 is granted. Mailed notice. (ecw, )
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Filing 135
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document exhibit #134 - Exhibit 4 to Nandi Declaration (Kelly, Adam)
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Filing 134
SEALED EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II - Exhibit 4 to Nandi Declaration regarding memorandum in opposition to motion, #133 (Kelly, Adam)
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Filing 133
MEMORANDUM by ABC Corporation I, ABC Corporation II in Opposition to motion for miscellaneous relief #129 (Attachments: #1 Declaration of Neil Nandi, #2 Exhibit 1 to Nandi Declaration, #3 Exhibit 2 to Nandi Declaration, #4 Exhibit 3 to Nandi Declaration)(Kelly, Adam)
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Filing 132
MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held by telephone on 12/15/2020. Motion to reassign case #122 is denied for the reasons stated on the record. Plaintiff's response to the Motion for Relief from the Preliminary Injunction Order #128 , #129 is due by 12/18/2020. Ebay's reply is due by close of business on 12/21/2020. A telephone conference is set for 12/22/2020 at 2:00 p.m. for a ruling on the motion. To join the telephone conference, dial 877-402-9757, Access Code 4410831. The 12/16/2020 motion hearing is vacated. Mailed notice. (ecw, )
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Filing 131
MINUTE entry before the Honorable Thomas M. Durkin: Motion to seal #126 is granted. Mailed notice. (ecw, )
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Filing 130
NOTICE of Motion by Richard A. Cederoth for presentment of motion for miscellaneous relief #129 , Sealed motion, #128 before Honorable Thomas M. Durkin on 12/16/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 129
MOTION by ThirdParty Plaintiff eBay, Inc.For Relief From the Preliminary Injunction Order (Redacted) (Cederoth, Richard)
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Filing 128
SEALED MOTION by ThirdParty Plaintiff eBay, Inc. for Relief from the Preliminary Injunction Order (Attachments: #1 Declaration of Paul J. Rogerson, #2 Exhibit 1 to Declaration of Paul J. Rogerson, #3 Exhibit 2 to Declaration of Paul J. Rogerson, #4 Exhibit 3 to Declaration of Paul J. Rogerson, #5 Exhibit 4 to Declaration of Paul J. Rogerson, #6 Declaration of Rebekah Long)(Cederoth, Richard)
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Filing 127
NOTICE of Motion by Richard A. Cederoth for presentment of motion to seal #126 before Honorable Thomas M. Durkin on 12/16/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 126
MOTION by ThirdParty Plaintiff eBay, Inc. to seal (Cederoth, Richard)
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Filing 125
MINUTE entry before the Honorable Thomas M. Durkin: Motion to seal document #124 is granted. Telephone hearing on the motion to reassign case #122 is set for 12/15/2020 at 9:00 a.m. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 124
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document exhibit, #123 (Nandi, Neil)
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Filing 123
SEALED EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II - Exhibit 2 - First Amended Complaint (20-cv-5905; NDIL) regarding MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to reassign case 20-cv-5905 as related under Local Rule 40.4 #122 (Nandi, Neil)
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Filing 122
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to reassign case 20-cv-5905 as related under Local Rule 40.4 (Attachments: #1 Exhibit 1 - Complaint (20-cv-5905; NDIL))(Nandi, Neil)
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Filing 121
CONSENT Judgment: Motion to approve consent judgment #120 is granted. Defendant XPRITINC is dismissed. Signed by the Honorable Thomas M. Durkin on 12/8/2020. Mailed notice. (ecw, )
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Filing 120
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to approve consent judgment between Plaintiffs Hangzhou Chic Intelligent Technology Co. and Unicorn Global, Inc. and Defendant XPRITINC (Kelly, Adam)
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Filing 119
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Bero Declaration (Redaction) regarding sealed document, #106 (Binns, Christopher)
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Filing 118
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Supplemental Declaration of Bero (Redacted) regarding sealed document, #106 (Binns, Christopher)
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Filing 117
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Declaration of Lei (Redacted) regarding sealed document, #81 (Binns, Christopher)
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Filing 116
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Declaration of Bero (Redacted) regarding sealed document, #81 (Binns, Christopher)
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Filing 115
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Declaration of Ying (Redacted) regarding sealed document, #21 (Binns, Christopher)
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Filing 114
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Declaration of Lei (Redacted) regarding sealed document #20 (Binns, Christopher)
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Filing 113
PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 11/24/2020. Mailed notice. (ecw, )
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Filing 112
MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 11/24/2020. For the reasons stated on the record, the motion for preliminary injunction #105 is granted. Enter order. Motion to file instanter oversized brief #108 is granted. Motion to seal document #109 is granted. Mailed notice. (ecw, )
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Filing 111
MINUTE entry before the Honorable Thomas M. Durkin: Telephone hearing as to motion to seal document #109 , motion for preliminary injunction #105 , motion to file instanter #108 set for 11/25/2020 is reset to 11/24/2020 at 9:00 a.m. To join the telephone call, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 110
NOTICE of Motion by Adam Glenn Kelly for presentment of motion to seal document #109 , motion for preliminary injunction #105 before Honorable Thomas M. Durkin on 11/25/2020 at 09:00 AM. (Kelly, Adam)
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Filing 109
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document, #106 , sealed document, #107 (Kelly, Adam)
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Filing 108
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to file instanter oversized brief (Kelly, Adam)
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Filing 107
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Declaration of Arthur Tan-Chi Yuan (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18)(Kelly, Adam)
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Filing 106
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Memorandum of Law in Support of Plaintiffs' Motion for Entry of a Preliminary Injunction (Attachments: #1 Exhibit A - Hatch Declaration, #2 Exhibit B - Bero Declaration, #3 Exhibit C - Ying Declaration, #4 Exhibit D - Lei Declaration, #5 Exhibit E - Nandi Declaration)(Kelly, Adam)
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Filing 105
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for preliminary injunction (Kelly, Adam)
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Filing 104
MINUTE entry before the Honorable Thomas M. Durkin: Motion for leave to file under seal #103 is granted. Mailed notice. (ecw, )
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Filing 103
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document,, #101 - Plaintiffs' Motion for Leave to File Under Seal their Third Amended Complaint and corresponding exhibits (Kelly, Adam)
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Filing 102
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II - Exhibit 3 regarding sealed document,, #101 (Attachments: #1 Exhibit 4)(Kelly, Adam)
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Filing 101
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Third Amended Complaint (Attachments: #1 Exhibit 1 - Part 1, #2 Exhibit 1 - Part 2, #3 Exhibit 1 - Part 3, #4 Exhibit 1 - Part 4, #5 Exhibit 1 - Part 5, #6 Exhibit 1 - Part 6, #7 Exhibit 1 - Part 7, #8 Exhibit 1 - Part 8, #9 Exhibit 1 - Part 9, #10 Exhibit 1 - Part 10, #11 Exhibit 1 - Part 11, #12 Exhibit 1 - Part 12, #13 Exhibit 2, #14 Schedule A, #15 Schedule B, #16 Schedule C)(Kelly, Adam)
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Filing 100
MINUTE entry before the Honorable Thomas M. Durkin: Motion for Leave to File Third Amended Complaint #97 is granted. Motion for leave to seal document #99 is granted. Mailed notice. (ecw, )
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Filing 99
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for Leave to File Third Amended Complaint #97 (Kelly, Adam)
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Filing 98
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Order re: Oakley, Inc. v. The Partnership and Unincorporated Associations Identified on Schedule "A" (20-cv-05972; NDIL) dated 11/11/2020; regarding SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for Leave to File Third Amended Complaint #97 (Kelly, Adam)
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Filing 97
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for Leave to File Third Amended Complaint (Attachments: #1 Declaration of Arthur Tan-Chi Yuan, #2 Third Amended Complaint with Exhibits, #3 Second Amended Complaint with Exhibits (Redline))(Kelly, Adam)
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Filing 96
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II NOVEMBER 4, 2020 JOINT STATUS REPORT OF PLAINTIFFS AND APPEARING DEFENDANTS (Kelly, Adam)
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Filing 95
MINUTE entry before the Honorable Thomas M. Durkin: Motion to withdraw #94 is granted. The motion hearing set for 11/5/2020 is vacated. Mailed notice. (ecw, )
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Filing 94
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to withdraw sealed document, #81 , motion for preliminary injunction #80 , sealed document, #82 MOTION TO WITHDRAW FOR PRELIMINARY INJUNCTION (Kelly, Adam)
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Filing 93
STATUS Report JOINT STATUS REPORT by ABC Corporation I, ABC Corporation II (Kelly, Adam)
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Filing 92
MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion to continue hearing #91 is granted. The hearing scheduled for 10/29/2020 at 9:00 a.m. on Plaintiffs' Motions #80 , #83 , and #84 is continued until 11/5/2020 at 9:00 a.m. and will proceed by telephone. To join the telephone hearing, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 91
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to continue UNOPPOSED MOTION TO CONTINUE HEARING (Kelly, Adam)
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Filing 90
NOTICE of Correction #88 , #87 , #86 (lma, )
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Filing 89
MINUTE entry before the Honorable Thomas M. Durkin: Telephone conference held on 10/26/2020. Parties are to submit a joint status report by 10/28/2020, regarding their positions on the pending motions. Motion to seal document #69 is granted. The motion hearing set for 10/29/2020 at 9:00 a.m. will proceed by telephone. To join the telephone hearing, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 88
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17575847. (Chen, Haoyi) (Duplicate filing of document number #86 Modified on 10/27/2020) (lma, ).
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Filing 87
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17575846. Haoyi Chen (Chen, Haoyi) (Duplicate filing of document number #86 Modified on 10/27/2020) (lma, ).
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Filing 86
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17575845. Haoyi Chen (Chen, Haoyi)
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Filing 85
NOTICE of Motion by Adam Glenn Kelly for presentment of motion to file instanter #84 , motion to seal document #83 , motion for preliminary injunction #80 before Honorable Thomas M. Durkin on 10/29/2020 at 09:00 AM. (Kelly, Adam)
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Filing 84
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to file instanter MOTION FOR LEAVE TO FILE, INSTANTER, OVERSIZED BRIEF (Kelly, Adam)
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Filing 83
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document, #81 , sealed document, #82 (Kelly, Adam)
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Filing 82
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II DECLARATION OF ARTHUR TAN-CHI YUAN (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18)(Kelly, Adam)
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Filing 81
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' MOTION FOR ENTRY OF A PRELIMINARY INJUNCTION (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Kelly, Adam)
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Filing 80
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II for preliminary injunction (Kelly, Adam)
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Filing 79
ATTORNEY Appearance for Plaintiffs ABC Corporation I, ABC Corporation II by Neil Gerard Nandi (Nandi, Neil)
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Filing 78
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Shen Wang (Wang, Shen)
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Filing 77
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Shen Wang (Wang, Shen)
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Filing 76
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Shen Wang (Wang, Shen)
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Filing 75
SEALED ORDER. Signed by the Honorable Thomas M. Durkin on 10/23/2020. Mailed notice. (ecw, )
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Filing 74
MINUTE entry before the Honorable Thomas M. Durkin: Unopposed motion for protective order #71 is granted. Motion to seal document #72 is granted. Enter order. Hearing on motion to file response under seal #69 set for 10/27/2020 is vacated, and will instead be heard during the telephone conference previously set for 10/26/2020 at 9:00 a.m. Mailed notice. (ecw, )
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Filing 73
NOTICE of Motion by Adam Glenn Kelly for presentment of motion to seal document #72 before Honorable Thomas M. Durkin on 10/27/2020 at 09:00 AM. (Kelly, Adam)
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Filing 72
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II MOTION FOR A PROTECTIVE ORDER #71 (Kelly, Adam)
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Filing 71
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II MOTION FOR A PROTECTIVE ORDER (Attachments: #1 Exhibit A)(Kelly, Adam)
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Filing 70
NOTICE of Motion by Adam Glenn Kelly for presentment of motion to seal document #69 before Honorable Thomas M. Durkin on 10/27/2020 at 09:00 AM. (Kelly, Adam)
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Filing 69
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed response, #68 (Kelly, Adam)
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Filing 68
SEALED RESPONSE by ABC Corporation I, ABC Corporation II to SEALED MOTION by ThirdParty Plaintiff eBay, Inc. To Dissolve The Ex Parte Temporary Restraining Order #56 PLAINTIFFS' OPPOSITION TO EBAY'S MOTION TO DISSOLVE (Kelly, Adam)
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Filing 67
MINUTE entry before the Honorable Thomas M. Durkin: This case has been reassigned to the calendar of Judge Durkin. A telephone status hearing is set for 10/26/2020 at 9:00 a.m. To join the telephone status hearing, dial 877-402-9757, Access Code 4410831. Mailed notice. (ecw, )
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Filing 66
EXECUTIVE COMMITTEE ORDER: Case reassigned to the Honorable Thomas M. Durkin for all further proceedings. Honorable Steven C. Seeger no longer assigned to the case. Signed by the Executive Committee on 10/19/2020. (sxb, )
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Filing 65
MINUTE entry before the Honorable Steven C. Seeger: The motion hearing set for October 21, 2020 (Dckt. No. #58 , #61 and #63 ) is hereby stricken. Mailed notice. (jjr, )
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Filing 64
MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. #47 ) is hereby granted. Docket nos. 44 & 46 are sealed. The motion stated that "Plaintiff will move to unseal these documents" after the "temporary restraining order has been served on the relevant parties and the requested actions are taken." Plaintiff's motion to seal the supplemental memorandum (Dckt. No. #49 ) is hereby granted. Docket no. 48 is sealed. The motion for leave to appeal pro hac vice (Dckt. No. #55 ) is hereby granted. Mailed notice. (jjr, )
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Filing 63
NOTICE of Motion by Richard A. Cederoth for presentment of motion to seal #62 before Honorable Steven C. Seeger on 10/21/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 62
MOTION by ThirdParty Plaintiff eBay, Inc. to seal (Cederoth, Richard)
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Filing 61
NOTICE of Motion by Richard A. Cederoth for presentment of motion to stay #59 before Honorable Steven C. Seeger on 10/21/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 60
SEALED DOCUMENT by ThirdParty Plaintiff eBay, Inc. Declaration of Paul J. Rogerson In Support of #59 Motion To Stay Ex Parte Temporary Restraining Order (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Cederoth, Richard)
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Filing 59
MOTION by ThirdParty Plaintiff eBay, Inc. to stay The Ex Parte Temporary Restraining Order As To eBay Inc. (Cederoth, Richard)
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Filing 58
NOTICE of Motion by Richard A. Cederoth for presentment of Sealed motion #56 before Honorable Steven C. Seeger on 10/21/2020 at 09:00 AM. (Cederoth, Richard)
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Filing 57
SEALED DOCUMENT by ThirdParty Plaintiff eBay, Inc. . Declaration of Rebekah Long In Support Of eBay Inc's Motion To Dissolve (Attachments: #1 Exhibit A)(Cederoth, Richard)
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Filing 56
SEALED MOTION by ThirdParty Plaintiff eBay, Inc. To Dissolve The Ex Parte Temporary Restraining Order (Cederoth, Richard)
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Filing 55
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17553303. (Rogerson, Paul)
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Filing 54
ATTORNEY Appearance for ThirdParty Plaintiff eBay, Inc. by Richard A. Cederoth (Cederoth, Richard)
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Filing 53
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Diego Fernando Freire (Freire, Diego)
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Filing 52
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Diego Fernando Freire (Freire, Diego)
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Filing 51
ATTORNEY Appearance for Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" by Diego Fernando Freire (Freire, Diego)
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Filing 50
MINUTE entry before the Honorable Steven C. Seeger: Plaintiffs' Ex Parte Motion to Extend Temporary Restraining Order (Dckt. No. #45 ) is hereby granted. The TRO is extended until 5:00 p.m. on October 20, 2020. Mailed notice. (jjr, )
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Filing 49
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document, #48 SUPPLEMENTAL MEMORANDUM IN SUPPORT OF PLAINTIFFS' EX PARTE MOTION TO EXTEND THE TEMPORARY RESTRAINING ORDER (Kelly, Adam)
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Filing 48
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II SUPPLEMENTAL MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION TO EXTEND THE TEMPORARY RESTRAINING ORDER (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Kelly, Adam)
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Filing 47
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed response, #44 , sealed document #46 , SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER #45 (Kelly, Adam)
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Filing 46
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION TO EXTEND THE TEMPORARY RESTRAINING ORDER #45 (Kelly, Adam)
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Filing 45
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER (Kelly, Adam)
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Filing 44
SEALED RESPONSE by ABC Corporation I, ABC Corporation II to order on motion to seal document,,,,,,, order on sealed motion,,,,,,,,,,,,,,,,,,,,,,,,,,,, text entry,,,,,, #41 (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Kelly, Adam)
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Filing 43
REGISTRY Deposit Information Form by Plaintiffs (sxb, )
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BOND in the amount of $ 94,000.00 posted by ABC Corporation I, ABC Corporation II Receipt number 4624246936
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SUMMONS Issued as to Defendant The Partnership and Unincorporated Associations Identified on Schedule "A" (exr, )
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Filing 42
SEALED TEMPORARY Restraining Order Signed by the Honorable Steven C. Seeger on 9/22/2020. Mailed notice. (jjr, )
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Filing 41
MINUTE entry before the Honorable Steven C. Seeger: Plaintiffs' ex parte motion for entry of a temporary restraining order (Dckt. No. #17 ) is granted in part. Order to follow. Plaintiffs' motion for electronic service under Rule 4(f)(3) (Dckt. No. #22 ) is granted. Plaintiffs' motion to seal (Dckt. No. #33 ) is granted. Plaintiffs' other motion to seal (Dckt. No. #39 ) is hereby granted. Plaintiffs make a rather weak showing of the need to file documents under seal. The notion is that Defendants could undercut a temporary restraining order by creating a new Amazon Standard Identification Number ("ASIN") and selling the same infringing products under the new ASIN. Plaintiffs never explain why filing the complaint and related documents under seal would prevent that outcome. Isn't there a risk that Defendants could do that anyway? Plaintiffs do not address the point, even though this Court raised it several weeks ago. (Dckt. No. #36 ) Still, given the risk of harm, the Court reluctantly will allow Plaintiffs to file the documents under seal for the time being. Plaintiffs' third motion to seal (Dckt. No. #40 ) is hereby granted. Again, the Court does so reluctantly. Plaintiffs repeated the generic justification for filing under seal (Dckt. No. #40 ), even though this Court expressly found that justification lacking last month. (Dckt. No. #28 ) By October 6, 2020, Plaintiffs shall file a statement that explains, with specificity, exactly how filing the documents under seal protected harm to Plaintiffs in this particular case. Mailed notice (jjr, ) (Docket Text Modified on 9/23/2020) (jjr, ).
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Filing 40
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document, #37 , SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT #37 UNDER SEAL AND RENEWED MOTION TO MAINTAIN DKT. NOS. 2-4, 10, 13-26 AND 30-32 UNDER SEAL #25 , #33 #39 (Kelly, Adam)
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Filing 39
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT #37 UNDER SEAL AND RENEWED MOTION TO MAINTAIN DKT. NOS. 2-4, 10, 13-26 AND 30-32 UNDER SEAL #25 , #33 (Attachments: #1 Exhibit A, #2 Exhibit B)(Kelly, Adam)
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Filing 38
EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II EXHIBITS 3 AND 4 regarding sealed document, #37 (Attachments: #1 Exhibit 4)(Kelly, Adam)
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Filing 37
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II SECOND AMENDED COMPLAINT (Attachments: #1 Exhibit 1 Part 1, #2 Exhibit 1 Part 2, #3 Exhibit 1 Part 3, #4 Exhibit 1 Part 4, #5 Exhibit 1 Part 5, #6 Exhibit 1 Part 6, #7 Exhibit 1 Part 7, #8 Exhibit 1 Part 8, #9 Exhibit 1 Part 9, #10 Exhibit 1 Part 10, #11 Exhibit 2, #12 Schedule A, #13 Redline)(Kelly, Adam)
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Filing 36
MINUTE entry before the Honorable Steven C. Seeger: On August 20, 2020, this Court issued an Order to show cause why the documents should not be unsealed, and why the complaint should not be stricken because Plaintiffs filed under pseudonyms without leave of Court, in violation of Rule 10(a). Plaintiffs' response (Dckt. No. #30 ) correctly notes that a party can file anonymously if there are exceptional circumstances, with leave of Court. See Doe v. Village of Deerfield, 819 F.3d 372, 377 (7th Cir. 2016). The need to protect state secrets, trade secrets, or victims of abuse are good examples. Id. But this case involves patent infringement, and Plaintiffs have not come close to satisfying the standard to proceed anonymously. The theory seems to be that Defendants potentially could see that a lawsuit was filed by Plaintiffs, and thus attempt to circumvent the case by creating new fictitious seller names and/or new Amazon Standard Identification Numbers. But it is unclear how filing anonymously would prevent Defendants from circumventing a future Court Order. Presumably Defendants could use new fictious seller names after this Court enters a TRO. A patent infringement case, without more, is not enough of a reason to circumvent the public disclosure requirements of the Federal Rules. Accordingly, the amended complaint (Dckt. No. #16 ) is hereby stricken. The Court grants Plaintiffs leave to file an amended complaint by September 18, 2020, but any amended complaint must use Plaintiffs' actual names, as required by Rule 10(a). If and when Plaintiffs file an amended complaint that complies with the Rules, the Court will address the pending motions. The Court notes that Plaintiffs' response did not address the second part of the order to show cause, that is, why the docket entries should not be unsealed. Mailed notice. (jjr, )
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Filing 35
MINUTE entry before the Honorable Steven C. Seeger: The motion hearing set for September 2, 2020 (Dckt. No. #34 ) is hereby stricken. Mailed notice. (jjr, )
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Filing 34
NOTICE of Motion by Adam Glenn Kelly for presentment of motion to seal document #33 before Honorable Steven C. Seeger on 9/2/2020 at 09:00 AM. (Kelly, Adam)
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Filing 33
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document sealed document, #31 , sealed response #30 , sealed document #32 (Kelly, Adam)
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Filing 32
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II SUPPLEMENTAL DECLARATION OF CLIENT REPRESENTATIVE IN SUPPORT OF RESPONSE #30 (Kelly, Adam)
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Filing 31
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II DECLARATION OF ARTHUR TAN-CHI YUAN IN SUPPORT OF RESPONSE #30 (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12)(Kelly, Adam)
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Filing 30
SEALED RESPONSE by ABC Corporation I, ABC Corporation II to order on motion to seal document,,,,,,,,,,, text entry,,,,,,,,,, #28 RESPONSE TO ORDER TO SHOW CAUSE (Attachments: #1 Exhibit A)(Kelly, Adam)
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Filing 29
MINUTE entry before the Honorable Steven C. Seeger: The motion hearing set for August 24, 2020 is hereby stricken. Mailed notice. (jjr, )
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Filing 28
MINUTE entry before the Honorable Steven C. Seeger: Plaintiffs' motion to seal (Dckt. No. #25 ) is denied without prejudice. Plaintiffs seek to seal a number of documents and hide them from public view, including information identifying the Defendants. The motion is conclusory, and does not muster much of a reason why this case cannot proceed out in the open. Plaintiffs claim that Defendants could "destroy relevant documentary evidence" and hide assets abroad, but that risk exists in many cases. This is a patent case, and it is standard practice for the parties to litigate in the public domain. By August 28, 2020, Plaintiffs shall show cause why the documents should not be unsealed. Also, Plaintiffs filed this case without identifying themselves in the complaint, in violation of the Federal Rules. They used pseudonyms, "ABC Corporation I" and "ABC Corporation II," without first requesting leave of court. (Dckt. No. #1 ) The motion to seal seeks leave to file an amended complaint under seal (which will "identify and include additional allegations regarding Plaintiff[s]"), but the motion did not seek leave to file an anonymous complaint in the first place. Rule 10(a) commands that the "title of the complaint must name all the parties." See Fed. R. Civ. P. 10(a). The duty to disclose one's own name is not a technicality, and it is not to be taken lightly. As the Seventh Circuit has explained, "We have repeatedly voiced our disfavor of parties proceeding anonymously, as anonymous litigation runs contrary to the rights of the public to have open judicial proceedings and to know who is using court facilities and procedures funded by public taxes. To proceed anonymously, a party must demonstrate exceptional circumstances that outweigh both the public policy in favor of identified parties and the prejudice to the opposing party that would result from anonymity." Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); see also In re Boeing 737 Max Pilots Litig., 2020 WL 247404 (N.D. Ill. 2020). Instead of providing the requisite information, the complaint involves claims by anonymous Plaintiffs against anonymous Defendants, and is chock-full of generic allegations about patent infringement. It deprives the public of any concrete information about what the dispute is about. By August 28, 2020, Plaintiffs shall show cause why the complaint should not be stricken. Mailed notice. (jjr, )
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Filing 27
ATTORNEY Appearance for Plaintiffs ABC Corporation I, ABC Corporation II by Christopher Gerald Binns (Binns, Christopher)
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Filing 26
NOTICE of Motion by Adam Glenn Kelly for presentment of Sealed motion, #17 , motion to seal document,,, #25 , Sealed motion #22 before Honorable Steven C. Seeger on 8/24/2020 at 09:00 AM. (Kelly, Adam)
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Filing 25
MOTION by Plaintiffs ABC Corporation I, ABC Corporation II to seal document exhibit, #2 , sealed document, #16 , exhibit #4 , sealed document #23 , sealed document #21 , sealed document, #19 , sealed document #20 , sealed document #24 , SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' MOTION FOR ELECTRONIC SERVICE OF PROCESS UNDER FED. R. CIV. P. 4(f)(3) #22 , sealed document #14 , sealed document #15 , sealed document, #18 , sealed document #13 , SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER, INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, AND EXPEDITED DISCOVERY #17 , exhibit #3 (Kelly, Adam)
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Filing 24
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II DECLARATION OF ARTHUR TAN-CHI YUAN IN SUPPORT OF PLAINTIFFS' MOTION #23 FOR ELECTRONIC SERVICE (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Kelly, Adam)
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Filing 23
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' MOTION #22 FOR ELECTRONIC SERVICE OF PROCESS UNDER FEDERAL RULE OF CIVIL PROCEDURE 4(f)(3) (Kelly, Adam)
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Filing 22
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' MOTION FOR ELECTRONIC SERVICE OF PROCESS UNDER FED. R. CIV. P. 4(f)(3) (Kelly, Adam)
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Filing 21
SEALED DOCUMENT by Plaintiff's ABC Corporation I, ABC Corporation II. DECLARATION regarding memorandum in support of motion #18 . (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Kelly, Adam) Docket Text Modified by Clerk's Office on 8/19/2020. (jh, ).
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Filing 20
SEALED DOCUMENT by Plaintiff's ABC Corporation I, ABC Corporation II. DECLARATION regarding memorandum in support of motion #18 . (Kelly, Adam) Docket Text Modified by Clerk's Office on 8/19/2020. (jh, ).
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Filing 19
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II DECLARATION OF ARTHUR TAN-CHI YUAN IN SUPPORT OF PLAINTIFFS' EX PARTE MOTION #18 FOR ENTRY OF A TEMPORARY RESTRAINING ORDER (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Kelly, Adam)
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Filing 18
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' EX PARTE MOTION #17 FOR ENTRY OF A TEMPORARY RESTRAINING ORDER, INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, AND EXPEDITED DISCOVERY (Kelly, Adam)
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Filing 17
SEALED MOTION by Plaintiffs ABC Corporation I, ABC Corporation II PLAINTIFFS' EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER, INCLUDING A TEMPORARY INJUNCTION, A TEMPORARY ASSET RESTRAINT, AND EXPEDITED DISCOVERY (Kelly, Adam)
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Filing 16
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II AMENDED COMPLAINT (Attachments: #1 Exhibit 1-1, #2 Exhibit 1-2, #3 Exhibit 1-3, #4 Exhibit 1-4, #5 Exhibit 1-5, #6 Exhibit 1-6, #7 Exhibit 1-7, #8 Exhibit 1-8, #9 Exhibit 1-9, #10 Exhibit 1-10, #11 Exhibit 2, #12 Exhibit 3, #13 Exhibit 4, #14 Schedule A, #15 Redline)(Kelly, Adam)
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Filing 15
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Notice of Claims Involving Patents (Kelly, Adam)
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Filing 14
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Notification of Affiliates pursuant to Local Rule 3.2 (Kelly, Adam)
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Filing 13
SEALED DOCUMENT by Plaintiffs ABC Corporation I, ABC Corporation II Notification of Affiliates pursuant to Local Rule 3.2 (Kelly, Adam)
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Filing 12
MINUTE entry before the Honorable Steven C. Seeger: Motion for Leave to Appear Pro Hac Vice (Dckt. No. #11 ) is granted. Attorney Christopher Gerald Binns is added as counsel of record for ABC Corporation I and ABC Corporation II. Mailed notice. (jjr, )
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Filing 11
MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17336750. (Binns, Christopher)
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Filing 10
MAILED SEALED Patent Report to Patent Trademark Office, Alexandria VA (sxb, )
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CASE ASSIGNED to the Honorable Steven C. Seeger. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (cp, )
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Filing 8
ATTORNEY Appearance for Plaintiffs ABC Corporation I, ABC Corporation II by Arthur Tan-chi Yuan (Yuan, Arthur)
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Filing 7
ATTORNEY Appearance for Plaintiffs ABC Corporation I, ABC Corporation II by Douglas N. Masters (Masters, Douglas)
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Filing 6
ATTORNEY Appearance for Plaintiffs ABC Corporation I, ABC Corporation II by Adam Glenn Kelly (Kelly, Adam)
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Filing 5
CIVIL Cover Sheet (Kelly, Adam)
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Filing 4
SEALED EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Schedule "A" regarding complaint #1 (Kelly, Adam)
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Filing 3
SEALED EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Exhibit 2 regarding complaint #1 (Kelly, Adam)
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Filing 2
SEALED EXHIBIT by Plaintiffs ABC Corporation I, ABC Corporation II Exhibit 1-1 regarding complaint #1 (Attachments: #1 Exhibit 1-2, #2 Exhibit 1-3, #3 Exhibit 1-4, #4 Exhibit 1-5, #5 Exhibit 1-6, #6 Exhibit 1-7, #7 Exhibit 1-8, #8 Exhibit 1-9, #9 Exhibit 1-10)(Kelly, Adam)
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Filing 1
COMPLAINT filed by ABC Corporation I, ABC Corporation II; Jury Demand. Filing fee $ 400, receipt number 0752-17333419. (Attachments: #1 Exhibit 3, #2 Exhibit 4)(Kelly, Adam)
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