Piechowicz v. The Partnerships and Unincorporated Associations Identified in Schedule A

AMENDED PRELIMINARY INJUNCTION ORDER: Based on the foregoing findings of fact and conclusions of law, Plaintiff's Motion for a Preliminary Injunction is hereby: 1. GRANTED against Defendants on the basis of Plaintiff's claims of copyright infringement, 2. It is ORDERED as follows: As sufficient causes have been shown, Defendants are temporarily enjoined and restrained from engaging in any of the following conduct pending the return date of the Application as referenced below: as further set forth in this Order. The temporary transfer of Defendants storefront effected under Plaintiffs Temporary Restraining Order shall immediately be in effect under this Preliminary Injunction, including that all e-commerce platforms operating or hosting Defendants and all Defendant owned or operated storefronts are to: as further set forth in this Order. This Preliminary Injunction Order is entered September 24, 2024, and shall remain in effect until final judgment is rendered in this action or the Court so orders otherwise. (Signed by Judge Vernon S. Broderick on 9/24/2024) (sgz) (Entered: 09/24/2024)

RESPONSE in Opposition to Motion re: 50 MOTION for Extension of Time -- Plaintiff's Ex Parte Motion to Extend TRO. . Document filed by RHCP, LLC..(Prager, Eric) (Entered: 08/16/2024)

***SELECTED PARTIES***DECLARATION of Mackenzie Paladino in Support re: 50 MOTION for Extension of Time -- Plaintiff's Ex Parte Motion to Extend TRO.. Document filed by Libby Piechowicz, RHCP, LLC. Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Entered: 08/16/2024)

***SELECTED PARTIES*** MOTION for Extension of Time -- Plaintiff's Ex Parte Motion to Extend TRO. Document filed by Libby Piechowicz, RHCP, LLC.Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Entered: 08/16/2024)

***SELECTED PARTIES***PROPOSED TEMPORARY RESTRAINING ORDER. Document filed by Libby Piechowicz. Related Document Number: 37 . Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 07/09/2024)

***SELECTED PARTIES***DECLARATION of Mackenzie Paladino in Support re: 37 MOTION for Temporary Restraining Order .. Document filed by Libby Piechowicz. (Attachments: # 1 Exhibit 1 to Declaration of Mackenzie Paladino, # 2 Exhibit 2 to Declaration of Mackenzie Paladino, # 3 Exhibit 3 to Declaration of Mackenzie Paladino)Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Entered: 07/09/2024)

***EX-PARTE*** MOTION for Temporary Restraining Order . Document filed by Libby Piechowicz.Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Refer to ECF Rule 13.19(b) and (c) for directions regarding promptly alerting the court to this filing.) (Entered: 07/09/2024)

***SELECTED PARTIES***DECLARATION of Mackenzie Paladino in Support re: 25 MOTION for Temporary Restraining Order .. Document filed by Libby Piechowicz. (Attachments: # 1 Exhibit 1 to Declaration of Mackenzie Paladino, # 2 Exhibit 2 to Declaration of Mackenzie Paladino, # 3 Exhibit 3 to Declaration of Mackenzie Paladino)Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Entered: 06/05/2024)

***EX-PARTE*** MOTION for Temporary Restraining Order . Document filed by Libby Piechowicz.Motion or Order to File Under Seal: 24 .(Paladino, Mackenzie) (Refer to ECF Rule 13.19(b) and (c) for directions regarding promptly alerting the court to this filing.) (Entered: 06/05/2024)

LETTER MOTION for Leave to File Ex Parte Motion for TRO and Other Relief Under Seal addressed to Judge Vernon S. Broderick from Plaintiff dated 5/13/2024. Document filed by Libby Piechowicz..(Paladino, Mackenzie) (Entered: 05/13/2024)

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's renewed motion for TRO 15 is denied without prejudice. The plaintiff has not complied with the Court's directive that the plaintiff's renewed filings "show that each defendant has contacts with the forum state," ECF No. 9 . While the plaintiff's declaration [15-2] avers that the defendant stores have made their products available "for sale to the United States, including Illinois," Piechowicz Decl. 8, the sealed exhibit 2 to the plaintiff's complaint [14-2] does not corroborate the plaintiff's contention because all instances of possible shipping addresses are redacted, thus raising concerns over whether the defendants are actively offering their goods for sale to Illinois residents. The plaintiff has leave to file a renewed motion properly establishing that each defendant has contacts with Illinoi by 3/12/24. Mailed notice (air, ) [Transferred from Illinois Northern on 4/22/2024.] (Entered: 02/27/2024)

SEALED MOTION by Plaintiff Libby Piechowicz -- Second Motion for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process By E-Mail And/Or Electronic Publication (Attachments: # 1 Memorandum in Support of Second Motion, # 2 Declaration of Libby Piechowicz, # 3 Declaration of Mackenzie Paladino, # 4 Exhibit 1 to Declaration of Mackenzie Paladino)(Paladino, Mackenzie) [Transferred from Illinois Northern on 4/22/2024.] (Entered: 02/23/2024)

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for TRO 8 is denied without prejudice. The Exhibit B to the sealed complaint contains numerous screenshots of purportedly infringing Amazon stores, but it fails to present them in an organized fashion, i.e., by noting which defendant marketplace each screenshot corresponds to, and which copyright(s) each defendant allegedly infringes. Furthermore, the Court notes that the screenshots do not demonstrate that the allegedly infringing products are being offered for sale in Illinois (including one storefront, which may not be offering its product for sale anywhere, as it is listed as "currently unavailable"). That evidence of purposefully directed activities is the bare minimum for establishing personal jurisdiction in schedule A cases. See NBA Properties, Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022), cert. denied, 143 S. Ct. 577 (2023). The plaintiff is granted leave to refile, as necessary, an amended complaint, schedule A, and/or renewed TRO with accompanying exhibits, which denotes which copyright each screenshot corresponds to, and which defendant is alleged to be responsible for infringing the identified copyright, by 2/26/24. The plaintiff must also show that each defendant has contacts with the forum state. Mailed notice (air, ) [Transferred from Illinois Northern on 4/22/2024.] (Entered: 02/12/2024)

SEALED MOTION by Plaintiff Libby Piechowicz for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery, and Service of Process by E-Mail and/or Electronic Publication (Attachments: # 1 Memorandum in Support of Motion, # 2 Declaration of Libby Piechowicz, # 3 Declaration of Mackenzie Paladino, # 4 Exhibit 1 to Declaration of Mackenzie Paladino)(Paladino, Mackenzie) [Transferred from Illinois Northern on 4/22/2024.] (Entered: 02/09/2024)