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1
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2023-12-15 |
COMPLAINT filed by Lando Norris; Filing fee $ 405, receipt number AILNDC-21428997. |
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Exhibit 1 |
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Exhibit 2 |
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Exhibit 3 |
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Exhibit 4 |
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2
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2023-12-15 |
SEALED EXHIBIT by Plaintiff Lando Norris Schedule A regarding complaint[1] |
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3
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2023-12-15 |
MOTION by Plaintiff Lando Norris for Leave to File Certain Documents Under Seal |
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4
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2023-12-15 |
CIVIL Cover Sheet |
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5
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2023-12-15 |
Notice of Claims Involving Trademarks by Lando Norris |
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6
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2023-12-15 |
ATTORNEY Appearance for Plaintiff Lando Norris by Martin Francis Trainor |
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7
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2023-12-15 |
ATTORNEY Appearance for Plaintiff Lando Norris by Richard M. Poskozim |
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8
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2023-12-15 |
ATTORNEY Appearance for Plaintiff Lando Norris by Sydney Paige Fenton |
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CASE ASSIGNED to the Honorable John F. Kness. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (Civil Category 2). |
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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. |
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9
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2023-12-19 |
MOTION by Plaintiff Lando Norris for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery |
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10
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2023-12-19 |
MEMORANDUM by Lando Norris in support of motion for miscellaneous relief[9] |
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Declaration of Martin F. Trainor |
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Exhibit 1 |
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11
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2023-12-19 |
DECLARATION of Paul Varley regarding memorandum in support of motion[10] |
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Exhibit 1 |
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12
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2023-12-19 |
SEALED EXHIBIT by Plaintiff Lando Norris |
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Exhibit 2-1 |
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Exhibit 2-2 |
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Exhibit 2-3 |
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Exhibit 2-4 |
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Exhibit 2-5 |
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Exhibit 2-6 |
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Exhibit 2-7 |
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Exhibit 2-8 |
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Exhibit 2-9 |
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(Exhibit 2-10) |
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13
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2023-12-19 |
MOTION by Plaintiff Lando Norris for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3) |
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14
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2023-12-19 |
MEMORANDUM by Lando Norris in support of motion for miscellaneous relief[13] |
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Declaration of Martin F. Trainor |
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Exhibit 1 |
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15
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2023-12-28 |
ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice. |
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16
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2024-01-16 |
Entered in Error. Modified on 1/16/2024. (Main Document 16 replaced on 1/16/2024). |
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17
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2024-01-18 |
ATTORNEY Appearance for Plaintiff Lando Norris by Alexander Whang |
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18
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2024-03-06 |
MAILED trademark report to Patent Trademark Office, Alexandria VA. |
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19
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2024-03-06 |
MAILED to plaintiff(s) counsel Lanham Mediation Program materials. |
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20
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2024-05-08 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for leave to file under seal [3], ex parte motion for a temporary restraining order [9], and motion for electronic service of process [13] are granted in part. Plaintiff's submissions (e.g., Dkt. [11], [12]) 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 for now file under seal the documents identified in the motion to seal and appearing at docket entries [2] and [12]. 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 (for the time being) on an ex parte basis under FRCP 65(b)(1). Specifically, and as noted above, were Defendants to be informed of this proceeding before a TRO could issue, it is likely assets and websites would be redirected, thus defeating Plaintiff's interests in identifying Defendants, stopping Defendants' infringing conduct, and obtaining the equitable accounting that, at this point, Plaintiff states that he may pursue. These facts justify, among other relief, the imposition of a prejudgment asset restraint against Defendants in an amount not to exceed $50,000 per separate account. In addition, the Court finds, at least for now on this limited and one-sided record and without prejudice to revisiting the issue, that it has personal jurisdiction over Defendants because they directly target their business activities toward consumers in the United States, including Illinois. Specifically, Defendants have targeted sales to Illinois residents by setting up and operating e-commerce stores that target United States consumers using one or more Seller Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars, and have sold products using infringing and counterfeit versions of Plaintiff's trademarked works to residents of Illinois. The evidence presented to the Court also shows that Plaintiff has demonstrated 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 and infringing 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. As several judges have previously noted, there may be reason to question both the propriety of joining all Defendants in this one action and whether Plaintiff will pursue an equitable accounting (which Plaintiff asserts as justification for an asset freeze), but at this preliminary stage, the Court is persuaded that Plaintiff has provided sufficient evidence of coordinated activity and the prospect of an accounting to justify the requested relief as to all Defendants. Expedited discovery is warranted to identify Defendants and to implement the asset freeze. If any Defendant appears and objects, the Court will reconsider the asset freeze and joinder. Enter Sealed Temporary Restraining Order. Mailed notice. |
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21
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2024-05-08 |
SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 5/8/2024. |
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SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified On Schedule A |
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22
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2024-05-14 |
MOTION by Attorney Richard Poskozim to withdraw as attorney for Lando Norris. No party information provided |
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23
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2024-05-16 |
MINUTE entry before the Honorable John F. Kness: Motion by counsel to withdraw as attorney [22] is granted. Attorney Richard M. Poskozim is withdrawn as counsel of record. Mailed notice. |
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26
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2024-05-16 |
SURETY BOND in the amount of $ 10,000.00 posted by Lando Norris. (Document not imaged) (Received at the Intake Counter on 05/16/2024.) |
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24
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2024-05-17 |
MOTION by Plaintiff Lando Norris to Extend the Temporary Restraining Order |
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25
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2024-05-17 |
MEMORANDUM by Lando Norris in support of motion for miscellaneous relief[24] |
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Declaration of Martin F. Trainor |
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27
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2024-05-21 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's Motion to extend the temporary restraining order [24] is granted. Enter separate order. Mailed notice. |
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28
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2024-05-21 |
EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable John F. Kness on 5/21/2024. Mailed notice. |
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29
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2024-05-31 |
SUMMONS Returned Executed by Lando Norris as to The Partnerships and Unincorporated Associations Identified On Schedule A on 5/31/2024, answer due 6/21/2024. |
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Declaration of Alexander Whang |
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Exhibit A |
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30
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2024-05-31 |
MOTION by Plaintiff Lando Norris for preliminary injunction |
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Exhibit A |
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31
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2024-05-31 |
MEMORANDUM by Lando Norris in support of motion for preliminary injunction[30] |
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Declaration of Martin F. Trainor |
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Exhibit 1 |
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32
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2024-06-07 |
NOTICE of Voluntary Dismissal by Lando Norris as to certain Defendants |
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33
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2024-06-11 |
NOTICE of Voluntary Dismissal by Lando Norris as to a certain Defendant |
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34
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2024-06-14 |
NOTICE of Voluntary Dismissal by Lando Norris as to certain Defendants |
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35
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2024-06-21 |
NOTICE of Voluntary Dismissal by Lando Norris as to certain Defendants |
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36
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2024-06-28 |
NOTICE of Voluntary Dismissal by Lando Norris as to a certain defendant |
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37
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2024-07-01 |
MINUTE entry before the Honorable John F. Kness: Plaintiff's motion for a preliminary injunction [30] is granted. Enter separate preliminary injunction order. Plaintiff's filings establish that Plaintiff 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 or infringing goods. Plaintiff has also certified and established [29] that it provided electronic notice to Defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no Defendant has objected to the motion for a preliminary injunction. Plaintiff's counsel is directed to ensure that all Defendants listed on Schedule A are added to the docket within five business days. The Clerk is directed to unseal any and all previously-sealed documents. Mailed notice. |
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38
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2024-07-01 |
PRELIMINARY INJUNCTION ORDER signed by the Honorable John F. Kness on 7/1/2024. Mailed notice. |
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NEW PARTIES: China Number Two Store, FashionBaseballcap Store, Felipe Drop-shipping Store, Free Love Clothing Store, Hytes Store, NewsNews84 Store, Sell Well Store, Shop1100386062 Store, Shop1102828387 Store, Shop1102853884 Store, Shop1102882235 Store, Shop1102900474 Store, Shop1103101180 Store, Shop1103106176 Store, Shop910370103 Store, YORIC Store, ZQ High End Boutique Clothing Store, A dim peak, A World Trip, AGE2X, Bella Home Co., binzhougaoxinquxiexiaobaihuodian, Calculate per capita, CanvasDushArt, careful yang, clock in wenchao, DuZhenWu, Emotional formula, Environmental Liu he, Fenfen exceeds, Flying repeatedly, hefeimangfazhadianzishangwuyouxiangongsi, Home sweetness, HUANGCHENGLIU, huijieshangmaoo, Huiteng Appreciation, KamranGalaxy, langjiangweimanhanri, Lanyue Art Shop, MA-star, MatissePOS, patience hui, Placing equipment, qixichengshangmao, Rod hammer, science yu znan, Sipa Sales LTD, Source of Victory, Southern resolution, space partitioning, TONG ANH 117 SHOP, WangDengWeng, Xianjie Store, Yang Brilliant, YangXiangJie01, yong Liu Shop, zhaozecongdjhye, A1S512XYXPYRZ9, leathercore, AllScaleStickers, ArgyleApparel, Cartive, CreativityMode, DoodledByChlo, dudeANDlaa, EverythingembDesigns, MyLegendArt, OMACPrints, PitStopPortraits, sportsprintsdirectt, stickYourself, The90thMinute, Abigail Evie, Adams Karlie, Andinet Manas, Binh Vu, Davis Davies, Eka Mei, Filippa Plyhm, Jean-Louis Glineur alias DeVerviers, Jeremy Owen, Lanna Beach, Mbendol Bento, Miguel Curiel, Nils Hedman, Richardson Stewart, Roberts Mason, Steve Palmer, Taylor Young, Theodor Decker, Wilmer Ekberg, fanlifeapparel, spoias, Devendra shah Devendra shah, Adirane Irene Wat Tambor, Bhupendra Patel, BilAllen, Blend_Hour-Long, Bobby Manifold, Camila Ribeiro, Casey Johnson, Chetan Joshi, Craig Russell, DanieBurke, DaviHead, DaviReynolds, DesignByUh, Eduardo Snchez, Edward Chan, FeithJewellery, FletcherDRoberson, GunnarDMiddleton, Ian Thomson, Igor Horvatic, Ishan Verma, Issy-Shaver, ItsarDesign, ItsartDesign, J lawn Carinc, Jar Jar Binks Crimson Emu, LeroyDCharles, Lovely Ciria, MandyIrwin, Maria Electorate, Ntombi, Ok Ex-Husband, Preceding_Amy, prettylittlestore, StreetCherub, Thandeka, TheMoneyTees, TimothyDNash, TShirtNova, TulipTee, Winston Coard, Zin, Matipe, 2D Tee Paradise, 36ahd, Aevthen, chenkai54632, chensiyu012, handandan fashion, i-infun, jinghanzu, li e, lvjie84610, MarlonEmmafElFuA, pinluoy, treefoptr, ttgfyuisdp, Tyrone Connor, wangtaotao8158, wuzhongli51394, zengyan87885, zhanglijia1213, zhangshutao1686, zhuzhoujia1872, Assessment location, chengll golden age, Liu Through, Meeting guo, Open Surround, Soldier CA, THUGIANGPT39, Yu Spring, KinemasterGB and USASports added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A |
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39
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2024-08-02 |
NOTICE of Voluntary Dismissal by Lando Norris as to certain Defendants |
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40
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2024-09-09 |
NOTICE of Voluntary Dismissal by Lando Norris as to a certain defendant |
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41
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2024-10-18 |
NOTICE of Voluntary Dismissal by Lando Norris as to a certain defendant |
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42
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2024-10-18 |
NOTICE of Voluntary Dismissal by Lando Norris as to a certain defendant |
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43
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2024-10-18 |
MOTION by Plaintiff Lando Norris for entry of default, MOTION by Plaintiff Lando Norris for default judgment as to all Defendants |
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Exhibit A |
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44
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2024-10-18 |
MEMORANDUM by Lando Norris in support of motion for entry of default, motion for default judgment[43] |
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Exhibit 1 |
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[+]
45
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2024-10-18 |
DECLARATION of Martin F. Trainor regarding memorandum in support of motion[44] |
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Exhibit 1 |
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46
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2024-10-24 |
ORDER: Plaintiff's motion for default judgment [43] is granted. Enter separate Final Judgment Order. Civil case terminated. Signed by the Honorable John F. Kness on 10/24/2024. Mailed notice. |
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47
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2024-10-24 |
FINAL JUDGMENT ORDER signed by the Honorable John F. Kness on 10/24/2024. Mailed notice. |
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48
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2024-10-25 |
MAILED trademark closing report with certified orders dated 10/24/2024 to Patent Trademark Office, Alexandria VA. |
