IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

____________________________________ 

 ) 

Trademark Holder Identified in Exhibit 1, ) Case No.: 20-cv-5256 

 ) 

 Plaintiff, ) 

 v. ) Judge: Honorable Sharon Johnson Coleman 

 ) 

Does 1-97, As Identified in Exhibit 2, ) 

 ) Magistrate: Honorable Sunil R. Harjani 

 Defendants. ) 

____________________________________) 

PRELIMINARY INJUNCTION ORDER 

Plaintiff, Good Life Ltd. dba Parker Baby Co. (“Good Life Ltd. dba Parker Baby Co.”), 

having filed its complaint for Federal Trademark Counterfeiting and Infringement, Unfair 

Competition and False Designation of Origin, claims under the Illinois Uniform Deceptive Trade 

Practices Act, and federal copyright infringement and having moved for a Preliminary injunction 

against the Defendants, and the Court having considered the complaint, declarations, exhibits, and 

memorandum of law filed in support, finds as follows: 

This Court hereby finds that it has personal jurisdiction over the Defendants because the 

Defendants directly target their business activities toward consumers in the United States, 

including the State of Illinois. Specifically, Defendants are reaching out to do business with Illinois 

residents by operating one or more commercial Internet webstores on platforms such as Amazon, 

eBay, Wish, Alibaba, or AliExpress, all which offer shipping to U.S. residents, including those 

within the jurisdiction of the Northern District of Illinois, through which Illinois residents can 

purchase products bearing counterfeit versions of the PARKER BABY CO. marked products, U.S. 

Reg. Nos. 5,681,477 and 5,493,989 (the “Marks”) (Dkt #2) as well as the use of the following 

Federal Copyright Registration Nos. VA 2-124-558, VA 2-202-663, and VA 2-208-962. These 

registrations are valid, unrevoked, and uncancelled. 

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This Court further finds that injunctive relief previously granted in the Temporary 

Restraining Order (“TRO”) (Dkt. #11) should remain in place through the pendency of this 

litigation and that issuing this Preliminary Injunction is warranted under FED. R. OF CIV. PRO. 65. 

Evidence submitted in support of this Motion and in support of Plaintiff’s previously granted 

Motion for Entry of a Temporary Restraining Order establishes that Plaintiff has a likelihood of 

success on the merits; that no remedy at law exists; and that Plaintiff will suffer irreparable harm if 

the injunction is not granted. 

Specifically, Plaintiff has proved a prima facie case of trademark infringement because (1) 

the PARKER BABY CO. Mark is distinctive and registered with the U.S. Patent and Trademark 

Office on the Principal Register; (2) Defendants are not licensed or authorized to use the PARKER 

BABY CO. Mark; and, (3) Defendant’s use of the PARKER BABY CO. Mark is causing a 

likelihood of confusion as to the origin or sponsorship of Defendants’ products with Plaintiff. 

Furthermore, Defendants’ continued and unauthorized use of Good Life Ltd. dba Parker 

Baby Co.’s Mark irreparably harms Plaintiff through diminished goodwill and brand confidence, 

damage to Plaintiff’s reputation, loss of exclusivity, and loss of future sales. Monetary damages 

fail to address such damage, and therefore Plaintiff has inadequate remedy at law. Moreover, the 

public interest is served by entry of this Preliminary Injunction to dispel the public confusion 

caused by Defendants’ actions. 

It is therefore ordered that:

I. Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, 

and all persons acting for, with, by, through, under or in active concert with them be 

enjoined and restrained from: 

a. using the PARKER BABY CO. trademark or any reproductions, counterfeit copies 

or colorable imitations thereof in any manner in connection with the distribution, 

marketing, advertising, offering for sale, or sale of any product that is not a genuine 

PARKER BABY CO. product or not authorized by Plaintiff to be sold in 

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connection with the PARKER BABY CO. Trademark; 

b. passing off, inducing, or enabling others to sell or pass off any product as a genuine 

PARKER BABY CO. product or any other product produced by Plaintiff, that is 

not Plaintiff’s or not produced under the authorization, control or supervision of 

Plaintiff and approved by Plaintiff for sale under the PARKER BABY CO. 

Trademark; 

c. committing any acts calculated to cause consumers to believe that Defendants’ 

Counterfeit Products are those sold under the authorization, control or supervision 

of Plaintiff, or are sponsored by, approved by, or otherwise connected with Good 

Life Ltd. dba Parker Baby Co.; 

d. further infringing the PARKER BABY CO. trademark and damaging Plaintiff’s 

goodwill; 

e. otherwise competing unfairly with Plaintiff in any manner; 

f. manufacturing, shipping, delivering, holding for sale, transferring or otherwise 

moving, storing, distributing, returning, or otherwise disposing of, in any manner, 

products or inventory not manufactured by or for Plaintiff, nor authorized by 

Plaintiff to be sold or offered for sale, and which bear any of the PARKER BABY 

CO. trademark, or any reproductions, counterfeit copies or colorable imitations 

thereof; 

g. using, linking to, transferring, selling, exercising control over, or otherwise owning 

or operating the infringing webstores, websites, or any other domain name that is 

being used to sell or is the means by which Defendants could continue to sell 

Counterfeit Products; and 

h. using any of Plaintiff’s copyrighted photographs or other images without 

authorization from Plaintiff. 

II. Defendants, their affiliates, officers, agents, servants, employees, attorneys, 

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confederates, and all persons acting for, with, by, through, under or in active concert with them be 

enjoined and restrained from: 

a. Moving, destroying, or otherwise disposing of any items, merchandise or 

documents relating to the Counterfeit Products, Defendants’ infringing webstores or 

websites, and/or Defendants’ assets and operation; 

b. Removing, destroying, or otherwise disposing of computer files, electronic files, 

business records, or documents relating to any of Defendants’ infringing webstores, 

websites, assets, operations, or relating in any way to the manufacture, acquisition, 

purchase, distribution or sale of Counterfeit Products, or any reproduction, copy or 

colorable imitation of the PARKER BABY CO. trademark; and 

c. Removing, destroying, or otherwise disposing of computer files, electronic files, 

business records, or documents relating to any of Defendants’ infringing webstores, 

websites, assets, operations, or relating in any way to the manufacture, acquisition, 

purchase, distribution or sale of Counterfeit Products, or any reproduction, copy or 

colorable imitation of the Plaintiff’s copyrights. 

III. Each Defendant and webstore (Amazon, eBay, Wish, Alibaba, AliExpress, etc.), within 

fourteen (14) days after receiving notice of this Order, shall serve upon Plaintiff a written report 

under oath providing: (a) their true name and physical address; (b) all websites and online 

marketplace accounts on any platform that they own and/operate; (c) documents sufficient to show 

total revenues generated from the sale of items hearing the PARKER BABY CO. trademark on 

their websites and other online marketplaces, including but not limited to all Amazon, eBay, Wish, 

Ali Express, Alibaba, PayPal,Western Union, Payoneer, Worldfirst, etcaccounts; and (d), for 

Defendants only, the steps taken by each Defendant to comply with paragraphs 

1(a)–(g) and 2(a)–(b), above. 

IV. Plaintiffs may immediately commence discovery by providing actual notice of this 

Order and an appropriate subpoena (if necessary) to any of the following parties: (1) Defendants, 

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their agents, servants, employees, confederates, attorneys, and any persons acting in concert or 

participation with them; (2) any online merchant platforms, banks, savings and loan associations, 

payment processors or other financial institutions, including without limitation, Amazon, eBay, 

Wish, Ali Express, AliBaba, PayPal, Inc., Western Union, Payoneer, Worldfirst, etc. or other 

merchant account providers, payment provider, third party processors, credit card associations (i.e. 

MasterCard and VISA) that receive payments or hold assets on Defendants’ behalf; and (3) any 

third party service providers, including without limitation, ISPs, back-end service providers, web 

designers, sponsored search engine or ad-word providers, shippers, domain name registrars, 

domain name registries or online third-party sellers who have provided services for Defendants 

(collectively, “Third Party Providers”) and they shall, within five (5) days after receipt of such 

notice, provide copies of all documents and records in such person or entity’s possession or control 

relating to: 

a. The identities and addresses of Defendants, their agents, servants, employees, 

confederates, and any persons acting in concert or participation with them and the locations and 

identities of Defendants’ operations, including without limitation, identifying information 

associated with Defendants’ infringing webstores websites and financial accounts; 

b. the nature of Defendants’ operations and all associated sales, methods of payment for 

services and financial information, including, without limitation, identifying information 

associated with the infringing websites and Defendants’ financial accounts, as well as providing a 

full accounting of Defendants’ sales and listing history related to the infringing websites; 

c. Defendants’ infringing webstores, websites and any domain name registered by 

Defendants; and 

d. Any financial accounts owned or controlled by Defendants, including their agents, 

servants, employees, confederates, attorneys, and any persons acting in concert or participation 

with them, including such accounts residing with or under the control of any banks, savings and 

loan associations, payment processors or other financial institutions, including without limitation, 

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Amazon, eBay, Wish, Ali Express, Alibaba, PayPal, Inc., Western Union, Payoneer, Worldfirst, or 

other merchant account providers, payment providers, third party processors, and credit card 

associations (i.e., MasterCard and VISA). 

V. Defendants and any persons in active concert or participation with them who have actual 

notice of this Order shall be restrained and enjoined from transferring or disposing of any money 

or other of Defendants’ assets until further ordered by this Court. 

VI. Amazon, eBay, Wish, Ali Express, Alibaba, and their affiliates shall, within two (2) 

business days of receipt of this Order, block any money transfers and funds from being transferred 

by the Defendants identified in Exhibit 2 of Plaintiff’s Complaint until further ordered by this 

Court. 

VII. PayPal, Inc., Payoneer, Worldfirst (“Payment Processors”) shall, within two (2) 

business days of receipt of this Order, for any Defendant or any of Defendants’ infringing 

websites: 

a. locate all accounts and funds utilized by Defendants and the infringing websites, 

including any Payment Processor and accounts affiliated with the information listed 

in Exhibit 2 of Plaintiff’s Complaint hereto; and 

b. restrain and enjoin any such accounts or funds from being transferred or disposed 

of until further ordered by this Court. 

VIII. Any banks, savings and loan associations, payment processors, or other financial 

institutions, for any Defendant or any of Defendants’ infringing websites, shall within two (2) 

business days of receipt of this Order: 

a. locate all accounts and funds utilized by Defendants and the infringing websites, 

including any financial accounts affiliated with the information listed in Schedule A 

hereto; and 

b. restrain and enjoin any such accounts or funds from being transferred or disposed of 

until further ordered by this Court. 

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IX. Plaintiff may provide notice of these proceedings to Defendants, including notice of 

the preliminary injunction hearing and service of process pursuant to FED. R. CIV. P. 4(f)(3), by 

by sending an e-mail to the e-mail addresses provided for Defendants by third parties hosting 

their webstores, such as Amazon, eBay, Wish, Ali Express, Alibaba, etc. Providing notice via email, along with any notice that Defendants receive from webstore hosts and payment processors, 

shall constitute notice reasonably calculated under all circumstances to apprise Defendants of the 

pendency of the action and afford them the opportunity to present their objections. 

X. This Order shall apply to the infringing webstores, websites and any other domain 

names properly brought to this Court’s attention and verified by sworn affidavit that verifies such 

new webstores or domain names are being used by Defendants for the purpose of counterfeiting 

the PARKER BABY CO. trademark at issue in this action and/or unfairly competing with 

Plaintiff. 

XI. Upon two (2) days’ written notice Plaintiff or on shorter notice as set by this Court, any 

Defendant may, upon proper showing, appear and move to dissolve or modify this Order upon an 

appropriate evidentiary showing by Defendant. 

XII. The $10,000 bond posted by Plaintiff shall remain with the Court until a final 

disposition of this case or until this Preliminary Injunction is terminated. 

DATED: October 26, 2020 _______________________________ 

 Sharon Johnson Coleman 

United States District Judge 

 

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