Hong Kong Leyuzhen Technology Co. Limited v. ABC Corporation

SURETY BOND in the amount of $ 1,000.00 posted by Hong Kong Leyuzhen Technology Co. Limited

ORDER FOR PRELIMINARY INJUNCTION Signed by the Honorable Edmond E. Chang on 04/22/2025. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the circumstances that justified entry of the TRO, the motion for preliminary injunction [25] is granted. Given the answer deadline of 05/12/2025, the tracking status hearing of 04/25/2025 for Judge Chang is reset to 05/30/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file an updated joint initial status report, R. 13-1, by 05/23/2025. If the Defendant does not answer on time, then it is deemed to be in default, and the Plaintiff shall instead file a motion for default judgment by 05/23/2025. The motion to deposit funds into Court Registry [23] is granted. Emailed notice

STATUS Report in Compliance with Docket 19 by Hong Kong Leyuzhen Technology Co. Limited

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for preliminary injunction, [25] before Honorable Edmond E. Chang on 4/25/2025 at 08:30 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for preliminary injunction

SUMMONS Returned Executed by Hong Kong Leyuzhen Technology Co. Limited as to ABC Corporation on 4/21/2025, answer due 5/12/2025.

NEW PARTIES: KAILINNA added to case caption.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited to deposit funds into Court Registry

SUMMONS Issued (Court Participant) as to Defendant KAILINNA

SUMMONS Submitted (Court Participant) for defendant(s) KAILINNA by Plaintiff Hong Kong Leyuzhen Technology Co. Limited

TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 04/14/2025. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion for temporary restraining order [16] is granted. An order will be entered separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion [4] for leave to file under seal is terminated as withdrawn: the courtroom deputy contacted the Plaintiff's counsel to inquire whether the TRO motion, which was publicly filed, was intended to be under seal, and the response was no. The Plaintiff's motion [14] for electronic service of process is granted for good cause and to provide reasonable notice. The motion [15] for extra pages is granted. The tracking status hearing of 04/18/2025 is reset to 04/25/2025 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the Plaintiff shall file a status report by 04/21/2025. The Plaintiff shall file, if appropriate, the TRO extension motion (or a preliminary injunction motion) no later than 04/21/2025. Emailed notice

STATUS Report in Compliance with Docket 13 by Hong Kong Leyuzhen Technology Co. Limited

Plaintiff's NOTICE of Motion by Joseph Wendell Droter for presentment of motion for leave to file excess pages[15], motion to seal, [4], motion for service by publication, [14], motion for temporary restraining order, [16] before Honorable Edmond E. Chang on 4/15/2025 at 08:30 AM.

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for temporary restraining order

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for leave to file excess pages for Temporary Restraining Order

MOTION by Plaintiff Hong Kong Leyuzhen Technology Co. Limited for service by publication and Electronic Service

MINUTE entry before the Honorable Edmond E. Chang: Initial tracking status hearing set for 04/18/2025 at 8:30 a.m. to track the case only (no appearance is required, the case will not be called). Instead, the Court will set the case schedule after reviewing the written status report. The parties must file a joint initial status report with the content described in the ***ATTACHED*** status report requirements (do ***not*** use templates from other cases) by 04/10/2025. Plaintiff must still file the report even if Defendant has not responded to requests to craft a joint report. If Defendant has not have been served, then Plaintiff must complete the part of the report on the progress of service. Also, counsel (or the parties, if proceeding pro se) must carefully review Judge Chang's Case Management Procedures, available online at ilnd.uscourts.gov (navigate to Judges / District Judges / Judge Edmond E. Chang). Because the Procedures are occasionally revised, counsel (or the party, if proceeding pro se) must read them anew even if the counsel or the party has appeared before Judge Chang in other cases. Emailed notice

MAILED copyright report to Registrar, Washington DC

MINUTE entry before the Executive Committee: Case reassigned to the Honorable Edmond E. Chang for all further proceedings pursuant to the provisions of 28 USC 294(b). Mailed notice

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Gokalp Bayramoglu

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Joseph Wendell Droter

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Nihat Deniz Bayramoglu

ATTORNEY Appearance for Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD by Katherine Marilyn Kuhn

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Exhibit 1 to the Declaration of K. Kuhn regarding MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal [4]

MOTION by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD to seal

CIVIL Cover Sheet

SEALED EXHIBIT by Plaintiff HONG KONG LEYUZHEN TECHNOLOGY CO., LTD Complaint for Copyright Infringement regarding complaint, [1]

COMPLAINT for Copyright Infringement filed by HONG KONG LEYUZHEN TECHNOLOGY CO., LTD; Jury Demand. Filing fee $ 405, receipt number AILNDC-23224176.

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 Joan H. Lefkow. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 3).