Revelyst Operations LLC v. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified in Schedule A Hereto
DEFAULT JUDGMENT ORDER as to certain defendants signed by the Honorable Jeffrey I Cummings on 10/27/2025. Mailed notice
73
2025/10/27
MINUTE entry before the Honorable Jeffrey I Cummings: The remaining defaulted defendants (excluding Wealucky and MIZUGIWA) have failed to respond to plaintiff's motion for default judgment. Accordingly, the motion 49 is granted. Based on the evidence previously submitted by plaintiff and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's marks irreparably harms plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. The court has considered the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants (plaintiff has failed to seek an accounting of profits), the value of plaintiff's brand, the need to deter infringement that is easily committed and difficult to stop, and the safety risk to the public of the counterfeit products at issue here. See e.g., Canada Goose v. Goosebb.com, No. 21-cv-1037, 2021 WL 4192881, at *3 (N.D.Ill. Apr. 15, 2021) (noting that because the counterfeit items were winter gear, "an inferior product actually poses a safety risk to consumers who might assume that it is more temperature resistant than it really is"). Based on these considerations, the Court concludes that $100,000 is an appropriate award of statutory damages. Enter Final Judgment Order as to certain defendants only. The case remains pending as to defendants Wealucky and MIZUGIWA. The previously set 10/3/25 tracking status hearing is stricken and reset to 12/5/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice
2025/10/24
NEW PARTIES: theopot, yyolo-us, Xinyouwei, FANGOSS, haoziyang123, KORADA, LOTGAUEN and Foshan Aplus Precision Hardware Co., Ltd added to case caption.
2025/10/24
NEW PARTIES: SPINA OPTICS STORE, Active-8, eoocvt, fmHome, BSGB, TOCNGAEK, Aeryoyo US, starrys sky, Donggaun Rongju E-commerce Co., Ltd, Yueoct, Bestsight Outdoor, wipboten, Dandelion Optical Instrument and Yihan Horizon added to case caption.
2025/10/24
NEW PARTIES: LONSEL, Miaozhun Store, kaihuazh, bestguarder, woltis, Miaozhun Jie Trade Co., Ltd., dophee, SHBYMYSH, Xisheng US, ACEXIER, Yifang Vision, PETPET22, WINFREE, KGlobal and SecurityIng added to case caption.
2025/10/24
NEW PARTIES: theopot, yyolo-us, Xinyouwei, FANGOSS, haoziyang123, KORADA, LOTGAUEN and Foshan Aplus Precision Hardware Co., Ltd added to case caption.
72
2025/10/23
PRELIMINARY INJUNCTION Order Signed by the Honorable Jeffrey I Cummings on 10/23/2025. Mailed notice
71
2025/10/23
MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for a preliminary injunction 28 is granted as to all remaining defendants excluding defendants Wealucky and MIZUGIWA. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established that it provided electronic notice to defendants of the pendency of this action and the motion, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order as to the remaining defendants excluding defendants Wealucky and MIZUGIWA. The motion remains pending as to defendants Wealucky and MIZUGIWA and the Court will issue a ruling in due course. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket. Mailed notice
70
2025/09/25
STATUS Report by Revelyst Operations LLC
69
2025/08/29
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
68
2025/08/26
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
67
2025/08/19
CERTIFICATE of Service Pursuant to Court's Minute Order (Dkt. 66) by Peter Krusiewicz on behalf of Revelyst Operations LLC regarding text entry, 66
66
2025/08/19
MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion 49 for entry of default and default judgment against all defaulting defendants (which does not include defendants Wealucky and MIZUGIWA. All remaining defaulting defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, an order of default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before 8/29/25. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice
65
2025/08/15
MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed plaintiff's status report on settlement 64, which indicates that the parties have discussed settlement and plaintiff is hopeful those discussions will continue. The Court encourages the parties to continue to meet and confer in an effort to resolve their dispute. They shall file a joint status report on settlement by 9/25/25. The 9/19/25 tracking status hearing is stricken and re-set to 10/3/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice.
64
2025/08/13
STATUS Report on Settlement re Dkt. 48 by Revelyst Operations LLC
63
2025/08/13
MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to withdraw and strike reply briefs 61 is granted in light of plaintiff's second corrected reply 60. The previously filed motion to withdraw and strike 59 is denied as moot. Mailed notice
62
2025/08/08
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
61
2025/08/07
MOTION by Plaintiff Revelyst Operations LLC to strike reply to response to motion, [58], memorandum in support of motion, [56] and Replace with Second Corrected Reply Brief [60]
60
2025/08/07
REPLY by Plaintiff Revelyst Operations LLC to memorandum in support of motion, [56] -- SECOND CORRECTED REPLY REPLACING [56] and [58] --
59
2025/08/07
MOTION by Plaintiff Revelyst Operations LLC to strike memorandum in support of motion, [56] and replace with Corrected Reply at Dkt. 58
58
2025/08/07
REPLY by Revelyst Operations LLC to memorandum in opposition to motion[45] -- CORRECTED REPLY BRIEF re DKT 56 --
57
2025/08/05
MINUTE entry before the Honorable Jeffrey I Cummings: In light of plaintiff's notice of voluntary dismissal of defendant Homesafety Electronic Co. 55, defendant's motion for extension of time to answer or otherwise plead 54 is denied as moot. Mailed notice. (jn,)
55
2025/08/01
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
54
2025/07/28
MOTION by Defendant Homesafety Electronic Co.,Ltd. for extension of time to file answer regarding complaint, 1
53
2025/07/28
NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Homesafety Electronic Co.,Ltd.
52
2025/07/28
ATTORNEY Appearance for Defendant Homesafety Electronic Co.,Ltd. by Ni Xue
51
2025/07/25
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to certain defendants
50
2025/07/24
MEMORANDUM by Revelyst Operations LLC in support of motion for default judgment 49
49
2025/07/24
MOTION by Plaintiff Revelyst Operations LLC for default judgment as to Defaulting Defendants
48
2025/07/23
MINUTE entry before the Honorable Jeffrey I Cummings: Defendants' motion for extension of time 43 is granted and the Court has since received the response brief filed by defendants Mizugiwa and Wealucky. Plaintiff's motion for extension of time to file a reply brief 46 is granted and plaintiff's reply in support of the motion for preliminary injunction is due 8/4/25. The parties are also encouraged to continue to engage in settlement negotiations and shall file a joint status report on settlement by 8/13/25. The previously set 6/20/25 tracking status hearing is stricken and re-set to 9/19/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice
47
2025/07/18
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
46
2025/07/18
MOTION by Plaintiff Revelyst Operations LLC for extension of time to file response/reply as to memorandum in opposition to motion 45 - UNOPPOSED MOTION TO EXTEND TIME FOR REPLY UNTIL AUG. 4 -
45
2025/07/12
MEMORANDUM by Wealucky in Opposition to motion for preliminary injunction 28
44
2025/07/11
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
43
2025/07/08
MOTION by Defendants MIZUGIWA, Wealucky for extension of time to file
42
2025/07/02
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
41
2025/06/27
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
40
2025/06/26
MINUTE entry before the Honorable Jeffrey I Cummings: Attorney Wenzhu Yu's motion for leave to appear pro hac vice 36 is granted. Attorney Whenzhu Yu's second motion for leave to appear pro hac vice 37 is denied as moot as only one pro hac vice request is required per proceeding. See Local Rule 83.14 ("A member in good standing of the bar of the highest court of any state of or any United States district court may, upon motion, be permitted to argue or try a particular case in whole or in part."). Mailed notice
39
2025/06/20
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
38
2025/06/13
NOTICE of Voluntary Dismissal by Revelyst Operations LLC -- as to certain defendants --
37
2025/06/11
MOTION for Leave to Appear Pro Hac Vice on behalf of Wealucky by YU WENZHU; Filing fee $ 150, receipt number AILNDC-23612338.
36
2025/06/11
MOTION for Leave to Appear Pro Hac Vice on behalf of MIZUGIWA by YU WENZHU; Filing fee $ 150, receipt number AILNDC-23612320.
35
2025/06/09
MINUTE entry before the Honorable Jeffrey I Cummings: The Court's 6/6/25 order 33 is amended to reflect that defendants BontokDirect and Anovo shall answer or otherwise plead by 7/16/25. Mailed notice
34
2025/06/06
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to certain defendants
33
2025/06/06
MINUTE entry before the Honorable Jeffrey I Cummings: Defendants BontokDirect and Anovo's unopposed motion for extension of time to answer or otherwise plead 32 is granted. Defendants BontokDirect and Anovo shall answer or otherwise plead by 6/16/25. Mailed notice. (jn,)
32
2025/06/03
MOTION by Defendants Anovo, BontokDirect for extension of time to file answer
31
2025/06/03
CERTIFICATE of Service by Peter Krusiewicz on behalf of Revelyst Operations LLC regarding text entry, 30
30
2025/06/03
MINUTE entry before the Honorable Jeffrey I Cummings: Before the Court is plaintiff's motion for entry of a preliminary injunction 28. In connection with that motion, plaintiff must serve all remaining defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no defendant appears and objects by or before June 13, 2025." If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining defendants within one business day of its entry on the docket and must promptly file proof of that service. For the reasons stated in the Court's order entering the TRO, the TRO is extended to and including the date upon which the Court adjudicates the motion for a preliminary injunction. See H-D Mich., LLC v. Hellenic Duty Free Shops S.A., 694 F.3d 827, 843-45 (7th Cir. 2012). Because this extension exceeds the maximum duration for a TRO under Fed.R.Civ.P. 65(b), this extension "becomes in effect a preliminary injunction that is appealable, but the order remains effective." Id. at 844. Mailed notice
29
2025/05/30
NOTICE of Voluntary Dismissal by Revelyst Operations LLC as to Certain Defendants
28
2025/05/30
MOTION by Plaintiff Revelyst Operations LLC for preliminary injunction
27
2025/05/22
SUMMONS Returned Executed by Revelyst Operations LLC as to All Defendants.
26
2025/05/22
SUMMONS Issued (Court Participant) as to Defendant BontokDirect
23
2025/05/21
MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion to extend the temporary restraining order 20 is granted. The TRO entered on 5/8/25 is extended to 6/5/25. Mailed notice
22
2025/05/20
ATTORNEY Appearance for Defendants BontokDirect, Anovo by Jing An
21
2025/05/13
SURETY BOND in the amount of $ 10,000.00 posted by Revelyst Operations LLC
20
2025/05/16
MOTION by Plaintiff Revelyst Operations LLC PLAINTIFF'S MOTION TO EXTEND TEMPORARY RESTRAINING ORDER
19
2025/05/16
Notice by Revelyst Operations LLC -- 10,000 USD surety bond deposited 05/13/25 --
18
2025/05/15
ATTORNEY Appearance for Defendant Jimtye by Qin Zhuang
17
2025/05/08
SEALED ORDER Signed by the Honorable Jeffrey I Cummings on 5/8/2025. Mailed notice
16
2025/05/08
MINUTE entry before the Honorable Jeffrey I Cummings: Plaintiff's motion for leave to file under seal 4, ex parte motion for a temporary restraining order, including a temporary injunction and a temporary asset restraint 10, and motion for expedited discovery, and for electronic service of process 15 are granted. Plaintiff's submissions establish that, were defendants to learn of these proceedings before the execution of plaintiff's requested preliminary injunctive relief, there is a significant risk that defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court. Accordingly, subject to unsealing at an appropriate time, plaintiff may file under seal the documents identified in the motion to seal. The Temporary Restraining Order being entered along with this minute order shall also be placed under seal. In addition, for the purpose of the motions cited above, plaintiff's filings support proceeding on an ex parte basis at this time. Specifically, and as noted above, were defendants to be informed of this proceeding before a TRO could issue, the Court finds that it is likely that their assets and websites would be redirected, thus defeating plaintiff's interests in identifying defendants, stopping defendants' infringing conduct, and obtaining an accounting. In addition, the evidence submitted by plaintiff shows a likelihood of success on the merits (including evidence of active infringement and sales into Illinois), that the harm to plaintiff is irreparable, and that an injunction is in the public interest. An injunction serves the public interest because of the consumer confusion caused by counterfeit goods, and there is no countervailing harm to defendants from an order directing them to stop infringement. 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. Expedited discovery is warranted to identify defendants and to implement the asset freeze. Enter Sealed Temporary Restraining Order. Status hearing is set for 6/20/25 at 9:00 a.m. to track the case only. (to track the case only, no appearance is required). Mailed notice
15
2025/04/16
MOTION by Plaintiff Revelyst Operations LLC FOR EXPEDITED DISCOVERY AND ELECTRONIC SERVICE
14
2025/04/16
MEMORANDUM by Revelyst Operations LLC -- MEMORANDUM ON JOINDER --
13
2025/04/16
SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT A TO THE DECLARATION OF MATTHEW A. WERBER (SEALED) regarding memorandum in support of motion, 11
12
2025/04/16
SEALED EXHIBIT by Plaintiff Revelyst Operations LLC EXHIBIT 1 TO THE DECLARATION OF PAUL MILLS (SEALED) regarding memorandum in support of motion, 11
11
2025/04/16
MEMORANDUM by Revelyst Operations LLC in support of motion for temporary restraining order 10 MEMORANDUM IN SUPPORT OF PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF
10
2025/04/16
MOTION by Plaintiff Revelyst Operations LLC for temporary restraining order PLAINTIFF'S EX PARTE MOTION FOR ENTRY OF A TEMPORARY RESTRAINING ORDER AND OTHER RELIEF
9
2025/04/14
ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Peter Krusiewicz
8
2025/04/14
MAILED to plaintiff(s) counsel Lanham Mediation Program materials.
2025/04/14
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.
2025/04/14
CASE ASSIGNED to the Honorable Jeffrey I Cummings. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 2).
7
2025/04/14
MAILED trademark report to Patent Trademark Office, Alexandria VA.
6
2025/04/11
ATTORNEY Appearance for Plaintiff Revelyst Operations LLC by Matthew A. Werber
5
2025/04/11
NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Revelyst Operations LLC
4
2025/04/11
MOTION by Plaintiff Revelyst Operations LLC to seal document exhibit 3
3
2025/04/11
SEALED EXHIBIT by Plaintiff Revelyst Operations LLC - Schedule A to Complaint - regarding complaint, 1
2
2025/04/11
CIVIL Cover Sheet
1
2025/04/11
COMPLAINT filed by Revelyst Operations LLC ; Filing fee $ 405, receipt number AILNDC-23339917.