John Doe v. The Individuals, Corporations, Limited Liability Companies, Partnerships and Unincorporated Associations Identified on Schedule A HeretoMOTIONN.D. Ill.June 18, 2020IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JOHN DOE, Plaintiff, v. THE INDIVIDUALS, CORPORATIONS, LIMITED LIABILITY COMPANIES, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A HERETO, Defendants. Case No. 20-cv-3558 Judge PLAINTIFF’S MOTION FOR LEAVE TO FILE UNDER SEAL Plaintiff John Doe (“Plaintiff”) files this Motion requesting leave to file the following documents under seal: (1) Plaintiff’s trademark registration certificates (Exhibit 1 to the Complaint); (2) Plaintiff’s copyright registration certificates (Exhibit 2 to the Complaint); (3) Plaintiff’s Schedule A attached to the Complaint, which identifies and includes a list of the Defendant Domain Names, domain name registration information, and Online Marketplace Accounts; and (4) screenshot printouts showing the active Defendant Internet Stores (Exhibit 3 to the Declaration of John Doe). In this action, Plaintiff is requesting temporary ex parte relief based on an action for trademark counterfeiting. Sealing this portion of the file is necessary to prevent the Defendants from learning of these proceedings prior to the execution of the temporary restraining order. If Defendants were to learn of these proceedings prematurely, the likely result would be the destruction of relevant documentary evidence and the hiding or transferring of assets to foreign 2 jurisdictions, which would frustrate the purpose of the underlying law and would interfere with this Court’s power to grant relief. Once the Amended Complaint is filed, the Temporary Restraining Order has been served on the relevant parties and the requested actions are taken, Plaintiff will move to unseal these documents. Respectfully submitted, Dated: June 18, 2020 By: s/Michael A. Hierl _ Michael A. Hierl (Bar No. 3128021) William B. Kalbac (Bar No. 6301771) Hughes Socol Piers Resnick & Dym, Ltd. Three First National Plaza 70 W. Madison Street, Suite 4000 Chicago, Illinois 60602 (312) 580-0100 Telephone (312) 580-1994 Facsimile mhierl@hsplegal.com Attorneys for Plaintiff John Doe 3 CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that a true and correct copy of the foregoing Motion for Leave to File Under Seal was filed electronically with the Clerk of the Court and served on all counsel of record and interested parties via the CM/ECF system on June 18, 2020. s/Michael A. Hierl
