Xia Zou

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Entered	Case	Description
10/30/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. The Court has conducted an initial review of the filings and noted several problems that must be remedied before this case will be allowed to proceed. First, the Complaint [1] identifies Plaintiff as "Patent Holder Identified in Exhibit 1", but Plaintiff has not sought leave to proceed anonymously. Even if Plaintiff had properly filed a motion for leave to proceed anonymously, such relief is not appropriate absent extraordinary circumstances not present in this case. See Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); Doe v. Loyola Univ. Chicago, 100 F.4th 910, 913 (7th Cir. 2024). Second, Exhibit A to the Declaration of Xia Zou [6-1] contains screenshots of Amazon checkout pages for products from only 3 of the 12 Defendants. Third, Schedule A to the Complaint [4] , Exhibit 1 to the Complaint [5] , the TRO motion [6] , and the Memorandum in Support of the TRO motion [7] were all filed provisionally under seal, but the motion to seal [8] seeks to seal only Schedule A [4] and the TRO motion [6] and related filings [7] and not Exhibit 1 [5] . Fourth, the TRO motion contains 4 pages of text and the Memorandum in Support of the TRO motion contains 15 pages of text, effectively violating Local Rule 7.1, but Plaintiff did not seek leave to exceed the page limit. Fifth, many of the filings contain drafting errors (e.g., the introduction to the Complaint refers to a non-existent "Second Amended Complaint"; the title of the motion to seal [8] misspells the word "under" as "udner"; the notice of presentment [9] refers to the correct judge (Judge Hunt) in the caption but the wrong judge (Judge Alexakis) in the body; the notice of presentment [9] states that a motion for electronic service will be presented, but no such motion has been filed). Last but not least, Plaintiff names 12 Defendants in this single case [4] ; however, the Court questions whether Plaintiff has established sufficient grounds for joinder. See 35 U.S.C. § 299; Tang v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 23 C 4587, 2024 WL 68332, at 1 (N.D. Ill. Jan. 4, 2024) ("accused infringers may not be joined in one action as defendants... based solely on allegations that they each have infringed the patent or patents in suit."). Rather than trying to resolve all these problems with piecemeal filings, the Court finds that it will be more efficient to start fresh. Accordingly, Plaintiff's Complaint [1] , Schedule A [4] , Exhibit 1 [5] , TRO motion [6] , Memorandum in Support of TRO motion [7] , and Notice of Presentment [9] are stricken. By 11/15/24, Plaintiff must file an amended complaint, including either (a) specific factual allegations and citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper; or (b) an amended Schedule A with a subset of Defendants, along with an amended declaration that explains how each of these Defendants is properly joined with each other and includes labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only. The Court will grant leave to file a renewed TRO motion after the joinder issue is resolved. Because the submissions establish that, were Defendants to learn of these proceedings before the execution of a temporary restraining order, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court, Plaintiff's motion to seal [8] is granted as follows: Schedule A [4] and Exhibit A to the Declaration of Xia Zou [6-1] (and any amendments to those documents) shall remain under seal pending further order of the Court; all other filings will be unsealed. The Clerk's Office is directed, forthwith, to (1) update the docket to reflect that the Plaintiff's name is "Xia Zou"; and (2) unseal Exhibit 1 [5] and the Declaration of Xia Zou [6] . Schedule A [4] and Exhibit A to the Declaration of Xia Zou [6-1] (and any amendments to those documents) shall remain under seal pending further order of the Court. No appearance is necessary on 11/5/24. Emailed notice. (cdh, ) (Entered: 10/30/2024) MINUTE entry before the Honorable LaShonda A. Hunt: This case has been assigned to the calendar of Judge LaShonda A. Hunt. The Court has conducted an initial review of the filings and noted several problems that must be remedied before this case will be allowed to proceed. First, the Complaint [1] identifies Plaintiff as "Patent Holder Identified in Exhibit 1", but Plaintiff has not sought leave to proceed anonymously. Even if Plaintiff had properly filed a motion for leave to proceed anonymously, such relief is not appropriate absent extraordinary circumstances not present in this case. See Doe v. Village of Deerfield, 819 F.3d 372, 376-77 (7th Cir. 2016); Doe v. Loyola Univ. Chicago, 100 F.4th 910, 913 (7th Cir. 2024). Second, Exhibit A to the Declaration of Xia Zou [6-1] contains screenshots of Amazon checkout pages for products from only 3 of the 12 Defendants. Third, Schedule A to the Complaint [4] , Exhibit 1 to the Complaint [5] , the TRO motion [6] , and the Memorandum in Support of the TRO motion [7] were all filed provisionally under seal, but the motion to seal [8] seeks to seal only Schedule A [4] and the TRO motion [6] and related filings [7] and not Exhibit 1 [5] . Fourth, the TRO motion contains 4 pages of text and the Memorandum in Support of the TRO motion contains 15 pages of text, effectively violating Local Rule 7.1, but Plaintiff did not seek leave to exceed the page limit. Fifth, many of the filings contain drafting errors (e.g., the introduction to the Complaint refers to a non-existent "Second Amended Complaint"; the title of the motion to seal [8] misspells the word "under" as "udner"; the notice of presentment [9] refers to the correct judge (Judge Hunt) in the caption but the wrong judge (Judge Alexakis) in the body; the notice of presentment [9] states that a motion for electronic service will be presented, but no such motion has been filed). Last but not least, Plaintiff names 12 Defendants in this single case [4] ; however, the Court questions whether Plaintiff has established sufficient grounds for joinder. See 35 U.S.C. § 299; Tang v. Partnerships & Unincorporated Associations Identified on Schedule A, No. 23 C 4587, 2024 WL 68332, at 1 (N.D. Ill. Jan. 4, 2024) ("accused infringers may not be joined in one action as defendants... based solely on allegations that they each have infringed the patent or patents in suit."). Rather than trying to resolve all these problems with piecemeal filings, the Court finds that it will be more efficient to start fresh. Accordingly, Plaintiff's Complaint [1] , Schedule A [4] , Exhibit 1 [5] , TRO motion [6] , Memorandum in Support of TRO motion [7] , and Notice of Presentment [9] are stricken. By 11/15/24, Plaintiff must file an amended complaint, including either (a) specific factual allegations and citations to specific screenshots associated with each Schedule A Defendant to demonstrate that joinder is proper; or (b) an amended Schedule A with a subset of Defendants, along with an amended declaration that explains how each of these Defendants is properly joined with each other and includes labeled exhibits that contain screenshots or other information specific to Defendants listed on amended Schedule A only. The Court will grant leave to file a renewed TRO motion after the joinder issue is resolved. Because the submissions establish that, were Defendants to learn of these proceedings before the execution of a temporary restraining order, there is a significant risk that Defendants could destroy relevant documentary evidence and hide or transfer assets beyond the reach of the Court, Plaintiff's motion to seal [8] is granted as follows: Schedule A [4] and Exhibit A to the Declaration of Xia Zou [6-1] (and any amendments to those documents) shall remain under seal pending further order of the Court; all other filings will be unsealed. The Clerk's Office is directed, forthwith, to (1) update the docket to reflect that the Plaintiff's name is "Xia Zou"; and (2) unseal Exhibit 1 [5] and the Declaration of Xia Zou [6] . Schedule A [4] and Exhibit A to the Declaration of Xia Zou [6-1] (and any amendments to those documents) shall remain under seal pending further order of the Court. No appearance is necessary on 11/5/24. Emailed notice. (cdh, ) (Entered: 10/30/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	NOTICE of Motion by Zheng Liu for presentment of Sealed motion [6] , motion to seal [8] before Honorable LaShonda A. Hunt on 11/5/2024 at 10:00 AM. (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	MOTION by Plaintiff Patent Holder Identified in Exhibit 1 to seal Schedule A [Dkt 4] and Motion for Entry of Restraining Order [Dkt 6 and 7] (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	SEALED DOCUMENT by Plaintiff Patent Holder Identified in Exhibit 1 Memorandum of Points and Authorities in Support of Plaintiff's Motion for Entry of Restraining Order (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	SEALED MOTION by Plaintiff Patent Holder Identified in Exhibit 1 Motion for Entry of Restraining Order (Attachments: # [1] Declaration in Support of Plaintiff's Ex Parte Motion for Entry of Restraining Order)(Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	SEALED DOCUMENT by Plaintiff Patent Holder Identified in Exhibit 1 Ex 1 attached to Complaint - asserted patent (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	SEALED DOCUMENT by Plaintiff Patent Holder Identified in Exhibit 1 Schedule A attached to Complaint - accused infringers (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	ATTORNEY Appearance for Plaintiff Patent Holder Identified in Exhibit 1 by Zheng Liu (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	CIVIL Cover Sheet (Liu, Zheng) (Entered: 10/29/2024)
10/29/24	Unknown case Title 1:24-CV-11092 ( N.D. IL )	ATTORNEY Appearance for Plaintiff Patent Holder Identified in Exhibit 1 by Jingyi Guo (Guo, Jingyi) (Entered: 10/29/2024)