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UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

George & Company LLC, a New 

York limited liability company, 

 ) 

) 

 ) 

 Plaintiff, ) 

 ) Case No. 20-cv-04673 

v. ) 

 ) Hon. John Robert Blakey 

Daniel Bekavac, an individual, 

Bekavac Trading Company, Inc., an 

Illinois corporation, and various 

John Does, Jane Does and ABC 

Companies, 

 ) 

) 

) 

) 

) 

Hon. Jeffrey Cole 

 ) 

 Defendants, ) 

Initial Status Report 

1. Type of Initial Status Report (e.g., Joint or Individual). This status report is filed by 

Plaintiff individually / singularly. Defendants have not obtained counsel or otherwise contacted 

Plaintiff or its counsel of record. 

2. Service of Process. Plaintiff initially attempted service upon both Defendants at the residence 

of Defendant Daniel Bekavac who is/was the registered agent and president of Defendant 

Bekavac Trading Company, Inc. (“BTC”). Despite the residence clearly being occupied, the 

process server’s attempt was unsuccessful. The following day, Defendants amended the BTC 

Articles of Incorporation with the Illinois Secretary of State to change the registered agent and 

address. Plaintiff attempted service upon BTC at the new address, however the new location did 

not identify either BTC or its new registered agent at the property. Plaintiff served BTC though 

the Illinois Secretary of State and attempted to serve Defendant Daniel Bekavac again at his 

residence. Again, despite the residence and property being clearly occupied and active, the 

attempt was unsuccessful. Plaintiff estimates that personal service of process upon Defendant 

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Daniel Bekavac will be completed within the next week, but if not, Plaintiff will promptly move 

the court for alternate service under Fed. R. Civ. P. 4. 

3. The Nature of the Case. 

a. The attorney of record is Adam E. Urbanczyk of AU LLC 564 W. Randolph St. 2nd 

Floor Chicago, IL 60661. Adam E. Urbanczyk is licensed to practice law in Illinois, 

Michigan, and the District of Columbia and admitted before the U.S. District Courts for 

the Northern and Central Districts of Illinois, the Eastern District of Michigan, and the 

District of Columbia. Adam E. Urbanczyk is not a member of the trial bar of the 

Northern District of Illinois. 

b. The basis for federal jurisdiction is Plaintiff’s claims arising under the Lanham Act and 

the U.S. Copyright Act, 28 U.S.C. §§ 1331, 1338. 

c. Plaintiff’s claims are based on federal trademark infringement, unfair competition under 

the Lanham Act and Illinois law, and copyright infringement. 

d. Plaintiff anticipates the major factual issues in the case to be: (i) whether Defendants 

were ever authorized to use the LCR Marks; (ii) whether Defendants were ever 

authorized to reproduce, distribute, and display the LCR Works; and (iii) whether BTC 

was simply an alter ego of Defendant Daniel Bekavac and to what extent Defendant 

Daniel Bekavac was personally involved in the infringement of Plaintiff’s rights in the 

LCR Marks and LCR Works. 

e. Plaintiff is aware that Defendant caused to be manufactured and obtained, without 

authorization, at least 20,000 units of a dice game bearing the LCR Marks and 

incorporating the LCR Works. Plaintiff’s LCR dice game retails for approximately 

$10/unit and Plaintiff believes that Defendants liquidated all of the product, resulting in 

earnings from the sale of counterfeit goods of at least approximately $200,000. Plaintiff 

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may separately seek statutory damages for Defendants’ willful infringement of the LCR 

Marks which would entitle Plaintiff to up to $2,000,000 for Defendants’ unauthorized, 

counterfeit use of each LCR Mark for each registered good or service. Plaintiff may 

separately seek statutory damages for Defendants’ willful infringement of the LCR 

Works which would entitle Plaintiff to up to $150,000 for Defendants’ unauthorized 

reproduction, distribution, and display of each LCR Work. Plaintiff is seeking injunctive 

relief, disgorgement of any profits, and reasonable attorneys’ fees and costs. 

4. Pending Motions and Case Plan. 

a. There are no pending motions. If Plaintiff is unable to obtain personal service upon 

Defendant Daniel Bekavac, Plaintiff will move the Court for leave to obtain service via 

alternative means. 

b. Proposal for discovery and Case Management Plan. 

1.Generally, Plaintiff will be seeking discovery related to BTC’s business dealings 

with Chinese suppliers and domestic third parties, including e-commerce 

businesses and platforms (e.g., Amazon.com). Plaintiff anticipates the need for 

some electronic discovery with respect to the Parties’ e-commerce activities. 

Plaintiff does not anticipate the need for bifurcated discovery. 

2.The Defendants have yet to appear and so identifying a date to produce initial 

disclosures under Rule 26(a)(1) may be premature. Plaintiff proposes that the 

Parties may propose a date, via a joint status report, once the Defendants appear 

and are engaged in the case. 

3.The Defendants have yet to appear and so identifying a date to first propound 

written discovery may be premature. Plaintiff proposes that the Parties may 

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propose a date, via a joint status report, once the Defendants appear and are 

engaged in the case. 

4.Plaintiff expects some discovery will concern sensitive financial records which 

the Parties will prefer to remain confidential. The Parties will endeavor to 

propose a confidentiality order, based on the Court’s model order, as soon as 

practicable. 

5.Plaintiff does not anticipate the need for any HIPAA waivers. 

6.The Defendants have yet to appear and so identifying a date by which fact 

discovery may be completed may be premature. Plaintiff proposes that the 

Parties may propose a date, via a joint status report, once the Defendants appear 

and are engaged in the case. 

7.The Defendants have yet to appear and so identifying a date by which expert 

discovery may be completed may be premature. Plaintiff proposes that the 

Parties may propose a date, via a joint status report, once the Defendants appear 

and are engaged in the case. 

8.The Defendants have yet to appear and so identifying a date by which dispositive 

motions, if any, may be filed may be premature. Plaintiff proposes that the 

Parties may propose a date, via a joint status report, once the Defendants appear 

and are engaged in the case. 

9.The Defendants have yet to appear and so identifying a trial date may be 

premature. Plaintiff proposes that the Parties may propose a date, via a joint 

status report, once the Defendants appear and are engaged in the case. 

10. Plaintiff does not now request a jury trial and anticipates a bench trial length 

of two days. 

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5. Consent to Proceed Before a Magistrate Judge. The Parties have not discussed with 

Defendants a request for assignment to Judge Cole. Plaintiff will discuss such assignment with 

Defendants once they entered the case and will notify the Court if the Parties consent to the 

assignment. 

6. Status of Settlement Discussions. The Parties have not discussed settlement. Plaintiff 

proposes that the Parties may request referral to a settlement conference, if it appears such a 

referral will be useful, once the Defendants appear and are engaged in the case. 

Dated: September 17, 2020 

Respectfully submitted, 

/s/Adam E. Urbanczyk 

AU LLC 

564 W. Randolph St. 2nd Floor 

Chicago, IL 60661 

adamu@au-llc.com 

Ph. (312) 715-7312 

Fax (312) 646-2501 

ARDC No. 6301067 

Counsel for Plaintiff George & Company 

LLC 

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Certificate of Service 

I hereby certify that the Initial Status Report will be sent via U.S. first-class mail to Defendants at 

their below respective addresses: 

Bekavac Trading Company, Inc. c/o ZAHID A MUNSHI 

6129 N HAMILTON AVE UNIT 2 

CHICAGO, IL 60659 

 

Daniel Bekavac Daniel Bekavac 

215 Slalom Ct. 

Minooka, IL 60447 

/s/Adam E. Urbanczyk 

AU LLC 

564 W. Randolph St. 2nd Floor 

Chicago, IL 60661 

adamu@au-llc.com 

Ph. (312) 715-7312 

Fax (312) 646-2501 

ARDC No. 6301067 

Counsel for Plaintiff George & Company 

LLC 

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