IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

HARDY WAY, LLC, )

) Case No. 20-cv-4854

Plaintiff, ) 

) Judge

v. )

)

THE INDIVIDUALS, CORPORATIONS, LIMITED )

LIABILITY COMPANIES, PARTNERSHIPS AND )

UNINCORPORATED ASSOCIATIONS IDENTIFIED )

ON SCHEDULE “A” HERETO, )

)

Defendants. )

COMPLAINT

Plaintiff HARDY WAY, LLC (“HARDY WAY” or “Plaintiff”), through undersigned 

counsel, hereby complains of the Partnerships, Unincorporated Associations and others identified 

in Schedule A attached hereto (collectively, “Defendants”), and for its Complaint hereby alleges

as follows:

JURISDICTION AND VENUE

1. This Court has original subject matter jurisdiction over the claims in this action 

pursuant to the provisions of the Lanham Act, 15 U.S.C. § 1051 et seq., 28 U.S.C. § 1338(a)–(b) 

and 28 U.S.C. § 1331. This Court has jurisdiction over the claims in this action that arise under 

the laws of the State of Illinois pursuant to 28 U.S.C. § 1367(a), because the state law claims are 

so related to the federal claims that they form part of the same case or controversy and derive 

from a common nucleus of operative facts.

2. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, and this Court may 

properly exercise personal jurisdiction over Defendants since each of the Defendants directly 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 1 of 16 PageID #:1
2

targets consumers in the United States, including Illinois, through at least the fully interactive 

commercial Internet stores operating under the Defendant Domain Names and/or the Online 

Marketplace Accounts identified in Schedule A attached hereto (collectively, the “Defendant 

Internet Stores”). Specifically, Defendants are reaching out to do business with Illinois residents 

by operating one or more commercial, interactive Internet Stores through which Illinois residents 

can purchase products bearing counterfeit versions of Plaintiff’s trademarks. Each of the 

Defendants have targeted sales from Illinois residents by operating online stores that offer 

shipping to the United States, including Illinois, accept payment in U.S. dollars and, on 

information and belief, has sold products bearing counterfeit versions of Plaintiff’s federally 

registered trademarks to residents of Illinois. Each of the Defendants is committing tortious acts 

in Illinois, is engaging in interstate commerce, and has wrongfully caused Plaintiff substantial 

injury in the State of Illinois.

INTRODUCTION

3. This action has been filed by Plaintiff to combat online counterfeiters who trade 

upon Plaintiff’s reputation and goodwill by selling and/or offering for sale products in connection 

with Plaintiff’s ED HARDY Trademarks, which are covered by U.S. Trademark Registration 

Nos. 4,424,478; 4,312,667; 3,135,603; 3,655,472; 3,141,658; 3,135,603 and 3,632,302

(collectively, the “ED HARDY Trademarks”). The Registrations are valid, subsisting, and in full 

force and effect. True and correct copies of the federal trademark registration certificates for the

marks are attached as Exhibit 1.

4. The Defendants create numerous Defendant Internet Stores and design them to 

appear to be selling genuine Plaintiff’s products, while selling inferior imitations of Plaintiff’s

products. The Defendant Internet Stores share unique identifiers, such as design elements and 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 2 of 16 PageID #:2
3

similarities of the counterfeit products offered for sale, establishing a logical relationship between 

them and suggesting that Defendants’ illegal operations arise out of the same transaction, 

occurrence, or series of transactions or occurrences. Defendants attempt to avoid liability by going 

to great lengths to conceal both their identities and the full scope and interworking of their illegal 

counterfeiting operation. Plaintiff is forced to file this action to combat Defendants’ counterfeiting

of Plaintiff’s registered trademarks, as well as to protect unknowing consumers from purchasing 

unauthorized ED HARDY products over the Internet. Plaintiff has been and continues to be 

irreparably damaged through consumer confusion, dilution, and tarnishment of its valuable 

trademarks as a result of Defendants’ actions and seeks injunctive and monetary relief.

5. This Court has personal jurisdiction over each Defendant, in that each Defendant

conducts significant business in Illinois and in this Judicial District, and the acts and events 

giving rise to this lawsuit of which each Defendant stands accused were undertaken in Illinois

and in this Judicial District. In addition, each Defendant has offered to sell and ship infringing 

products into this Judicial District.

THE PLAINTIFF

6. Plaintiff HARDY WAY, LLC is a limited liability company organized and 

existing under the laws of Delaware having a place of business at 1450 Broadway, 3rd Floor, 

New York, NY 10018.

7. Plaintiff HARDY WAY, LLC is the registered owner of the ED HARDY 

Trademarks (U.S. Trademark Registration Nos. 4,424,478; 4,312,667; 3,135,603; 3,655,472;

3,141,658; 3,135,603 and 3,632,302). HARDY WAY is in the business of developing, 

marketing, selling and distributing Ed Hardy products. Ed Hardy is an alternative lifestyle 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 3 of 16 PageID #:3
4

fashion brand that celebrates the classic American tattoo as an art form. HARDY WAY, LLC is 

the official source of Ed Hardy products:

https://edhardyoriginals.com/collections/all

8. Since at least September 30, 2003, the ED HARDY Trademarks have been the 

subject of substantial and continuous marketing and promotion by Plaintiff. Plaintiff has and 

continues to widely market and promote the ED HARDY Trademarks in the industry and to 

consumers. Plaintiff’s promotional efforts include — by way of example, but not limitation —

website and social media sites, and point of sale materials.

9. The ED HARDY Trademarks are distinctive and identify the merchandise as 

goods from Plaintiff. The registrations for the ED HARDY Trademarks constitute prima facie

evidence of their validity and of Plaintiff’s exclusive right to use the ED HARDY Trademarks

pursuant to 15 U.S.C. § 1057(b).

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 4 of 16 PageID #:4
5

10. The ED HARDY Trademarks qualify as famous marks, as that term is used in 15 

U.S.C. §1125 (c)(1) and have been continuously used and never abandoned.

11. Plaintiff has expended substantial time, money, and other resources in developing, 

advertising, and otherwise promoting the ED HARDY Trademarks. As a result, products bearing 

the ED HARDY Trademarks are widely recognized and exclusively associated by consumers, 

the public, and the trade as being products sourced from Plaintiff.

THE DEFENDANTS

12. Defendants are individuals and business entities who, upon information and 

belief, reside in the People’s Republic of China or other foreign jurisdictions. Defendants 

conduct business throughout the United States, including within Illinois and in this Judicial 

District, through the operation of fully interactive commercial websites and online marketplaces 

operating under the Defendant Internet Stores. Each Defendant targets the United States, 

including Illinois, and has offered to sell and, on information and belief, has sold and continues 

to sell counterfeit ED HARDY products to consumers within the United States, including Illinois

and in this Judicial District.

THE DEFENDANTS’ UNLAWFUL CONDUCT

13. The success of the ED HARDY brand has resulted in its counterfeiting. Plaintiff

has identified numerous domain names linked to fully interactive websites and marketplace 

listings on platforms such as iOffer and Aliexpress, Alipay, DHgate, eBay and PayPal, including 

the Defendant Internet Stores, which were offering for sale, selling, and importing counterfeit 

ED HARDY products to consumers in this Judicial District and throughout the United States.

Defendants have persisted in creating the Defendant Internet Stores. Internet websites like the 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 5 of 16 PageID #:5
6

Defendant Internet Stores are estimated to receive tens of millions of visits per year and to 

generate over $135 billion in annual online sales. According to an intellectual property rights

seizures statistics report issued by Homeland Security, the manufacturer’s suggested retail price 

(MSRP) of goods seized by the U.S. government in fiscal year 2017 was over $1.21 billion. 

Internet websites like the Defendant Internet Stores are also estimated to contribute to tens of 

thousands of lost jobs for legitimate businesses and broader economic damages such as lost tax

revenue every year.

14. Upon information and belief, Defendants facilitate sales by designing the 

Defendant Internet Stores so that they appear to unknowing consumers to be authorized online 

retailers, outlet stores, or wholesalers selling genuine ED HARDY products. Many of the 

Defendant Internet Stores look sophisticated and accept payment in U.S. dollars via credit cards, 

Western Union and PayPal, Alipay and DHgate. Defendant Internet Stores often include images 

and design elements that make it very difficult for consumers to distinguish such counterfeit sites 

from an authorized website. Defendants further perpetuate the illusion of legitimacy by offering

“live 24/7” customer service and using indicia of authenticity and security that consumers have 

come to associate with authorized retailers, including the McAfee® Security, VeriSign®, Visa®, 

MasterCard®, and PayPal® logos. 

15. Plaintiff has not licensed nor authorized Defendants to use the ED HARDY 

Trademarks, and none of the Defendants are authorized retailers of genuine ED HARDY 

products.

16. Upon information and belief, Defendants also deceive unknowing consumers by 

using the ED HARDY Trademarks without authorization within the content, text, and/or meta tags 

of their websites to attract various search engines crawling the Internet looking for websites 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 6 of 16 PageID #:6
7

relevant to consumer searches for ED HARDY products. Additionally, upon information and 

belief, Defendants use other unauthorized search engine optimization (SEO) tactics and social 

media spamming so that the Defendant Internet Store listings show up at or near the top of relevant 

search results and misdirect consumers searching for genuine ED HARDY products. Further, 

Defendants utilize similar illegitimate SEO tactics to propel new domain names to the top of 

search results after others are shut down. As such, Plaintiff also seeks to disable Defendant 

Domain Names owned by Defendants that are the means by which the Defendants could 

continue to sell counterfeit ED HARDY products.

17. Defendants go to great lengths to conceal their identities and often use multiple 

fictitious names and addresses to register and operate their massive network of Defendant Internet 

Stores. For example, many of Defendants’ names and physical addresses used to register the 

Defendant Domain Names are incomplete, contain randomly typed letters, or fail to include cities 

or states. Other Defendant Domain Names use privacy services that conceal the owners’ identity 

and contact information. Upon information and belief, Defendants regularly create new websites 

and online marketplace accounts on various platforms using the identities listed in Schedule A to 

the Complaint, as well as other unknown fictitious names and addresses. Such Defendant Internet 

Store registration patterns are one of many common tactics used by the Defendants to conceal their

identities, the full scope and interworking of their massive counterfeiting operation, and to avoid 

being shut down.

18. Even though Defendants operate under multiple fictitious names, there are numerous 

similarities among the Defendant Internet Stores. For example, some of the Defendant websites 

have virtually identical layouts, even though different aliases were used to register the respective 

domain names. In addition, the counterfeit ED HARDY products for sale in the Defendant Internet 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 7 of 16 PageID #:7
8

Stores bear similarities and indicia of being related to one another, suggesting that the counterfeit 

ED HARDY products were manufactured by and come from a common source and that, upon 

information and belief, Defendants are interrelated. The Defendant Internet Stores also include other 

notable common features, including use of the same domain name registration patterns, unique 

shopping cart platforms, accepted payment methods, check-out methods, meta data, illegitimate 

SEO tactics, HTML user-defined variables, domain redirection, lack of contact information, 

identically or similarly priced items and volume sales discounts, similar hosting services, similar 

name servers, and the use of the same text and images. 

19. In addition to operating under multiple fictitious names, Defendants in this case

and defendants in other similar cases against online counterfeiters use a variety of other common 

tactics to evade enforcement efforts. For example, counterfeiters like Defendants will often 

register new domain names or online marketplace accounts under new aliases once they receive 

notice of a lawsuit. Counterfeiters also often move website hosting to rogue servers located 

outside the United States once notice of a lawsuit is received. Rogue servers are notorious for 

ignoring take down demands sent by brand owners. Counterfeiters also typically ship products in 

small quantities via international mail to minimize detection by U.S. Customs and Border 

Protection. A 2012 U.S. Customs and Border Protection report on seizure statistics indicated that 

the Internet has fueled “explosive growth” in the number of small packages of counterfeit goods 

shipped through the mail and express carriers.

20. Further, counterfeiters such as Defendants typically operate multiple credit card 

merchant accounts and Aliexpress, Alipay, DHgate, eBay and PayPal accounts behind layers of 

payment gateways so that they can continue operation in spite of Plaintiff’s enforcement efforts. 

Upon information and belief, Defendants maintain off-shore bank accounts and regularly move 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 8 of 16 PageID #:8
9

funds from their Aliexpress, Alipay, DHgate, eBay and PayPal accounts to off-shore bank 

accounts outside the jurisdiction of this Court. Indeed, analysis of Aliexpress, Alipay, DHgate, 

eBay and PayPal transaction logs from previous similar cases indicates that offshore counterfeiters

regularly move funds from U.S.-based Aliexpress, Alipay, DHgate, eBay and PayPal accounts to 

China-based bank accounts outside the jurisdiction of this Court.

21. Defendants, without any authorization or license from Plaintiff, have knowingly 

and willfully used and continue to use the ED HARDY Trademarks in connection with the 

advertisement, distribution, offering for sale, and sale of counterfeit ED HARDY products into 

the United States and Illinois over the Internet. Each Defendant Internet Store offers shipping to 

the United States, including Illinois and, on information and belief, each Defendant has offered 

to sell counterfeit ED HARDY products into the United States, including Illinois.

22. Defendants’ use of the ED HARDY Trademarks in connection with the 

advertising, distribution, offering for sale, and sale of counterfeit ED HARDY products, 

including the sale of counterfeit ED HARDY products into Illinois, is likely to cause and has 

caused confusion, mistake, and deception by and among consumers and is irreparably harming 

Plaintiff.

COUNT I

TRADEMARK INFRINGEMENT AND COUNTERFEITING (15 U.S.C. § 1114)

23. Plaintiff repeats and incorporates by reference herein the allegations contained in 

paragraphs 1-22 of this Complaint.

24. This is a trademark infringement action against Defendants based on their 

unauthorized use in commerce of counterfeit imitations of the registered ED HARDY 

Trademarks in connection with the sale, offering for sale, distribution, and/or advertising of 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 9 of 16 PageID #:9
10

infringing goods. The ED HARDY Trademarks are highly distinctive marks. Consumers have 

come to expect the highest quality from Plaintiff’s products provided under the ED HARDY 

Trademarks.

25. Defendants have sold, offered to sell, marketed, distributed, and advertised, and 

are still selling, offering to sell, marketing, distributing, and advertising products in connection 

with the ED HARDY Trademarks without Plaintiff’s permission.

26. The United States Registrations for the ED HARDY Trademarks (Exhibit 1) are

in full force and effect. Upon information and belief, Defendants have knowledge of Plaintiff’s

rights in the ED HARDY Trademarks and are willfully infringing and intentionally using 

counterfeits of the ED HARDY Trademarks on counterfeit goods. Defendants’ willful, 

intentional, and unauthorized use of the ED HARDY Trademarks is likely to cause and is 

causing confusion, mistake, and deception as to the origin and quality of the counterfeit goods 

among the general public.

27. Defendants’ activities constitute willful trademark infringement and 

counterfeiting under 15 U.S.C. §§ 1114, 1117.

28. The injuries and damages sustained by Plaintiff has been directly and proximately 

caused by Defendants’ wrongful reproduction, use, advertisement, promotion, offering to sell,

and sale of counterfeit ED HARDY products.

29. Plaintiff has no adequate remedy at law, and, if Defendants’ actions are not 

enjoined, Plaintiff will continue to suffer irreparable harm to its reputation and the goodwill of its

well-known ED HARDY Trademarks.

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 10 of 16 PageID #:10
11

COUNT II

FALSE DESIGNATION OF ORIGIN (15 U.S.C. § 1125(a))

30. Plaintiff repeats and incorporates by reference herein the allegations contained in 

paragraphs 1-29 of this Complaint.

31. Defendants’ promotion, marketing, offering for sale, and sale of counterfeit ED 

HARDY products has created and is creating a likelihood of confusion, mistake, and deception 

among the general public as to the affiliation, connection, or association with Plaintiff or the origin, 

sponsorship, or approval of Defendants’ counterfeit ED HARDY products by Plaintiff.

32. By using the ED HARDY Trademarks in connection with the sale of counterfeit 

ED HARDY products, Defendants create a false designation of origin and a misleading

representation of fact as to the origin and sponsorship of the counterfeit ED HARDY products.

33. Defendants’ false designation of origin and misrepresentation of fact as to the 

origin and/or sponsorship of the counterfeit ED HARDY products to the general public is a 

willful violation of Section 43 of the Lanham Act, 15 U.S.C. § 1125.

34. Plaintiff has no adequate remedy at law and, if Defendants’ actions are not 

enjoined, Plaintiff will continue to suffer irreparable harm to its reputation and the goodwill of its 

brand.

COUNT III 

VIOLATION OF ILLINOIS UNIFORM DECEPTIVE TRADE PRACTICES ACT

(815 ILCS § 510/1, et seq.)

35. Plaintiff repeats and incorporates by reference herein the allegations contained in 

paragraphs 1-34 of this Complaint.

36. Defendants have engaged in acts violating Illinois law including, but not limited 

to, passing off their counterfeit ED HARDY products as those of Plaintiff, causing a likelihood 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 11 of 16 PageID #:11
12

of confusion and/or misunderstanding as to the source of their goods, causing a likelihood of 

confusion and/or misunderstanding as to an affiliation, connection, or association with genuine 

ED HARDY products, representing that their products have Plaintiff’s approval when they do

not, and engaging in other conduct which creates a likelihood of confusion or misunderstanding 

among the public.

37. The foregoing Defendants’ acts constitute a willful violation of the Illinois

Uniform Deceptive Trade Practices Act, 815 ILCS § 510/1, et seq.

38. Plaintiff has no adequate remedy at law, and Defendants’ conduct has caused 

Plaintiff to suffer damage to its reputation and goodwill. Unless enjoined by the Court, Plaintiff

will suffer future irreparable harm as a direct result of Defendants’ unlawful activities.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants and each of them as 

follows:

1) That 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 temporarily, preliminarily, and permanently enjoined and restrained from:

a. using the ED HARDY Trademarks 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 products that are not genuine

ED HARDY products or are not authorized by Plaintiff to be sold in connection with 

the ED HARDY Trademarks;

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

ED HARDY products or any other products produced by Plaintiff that are not 

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 12 of 16 PageID #:12
13

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

and approved by Plaintiff for sale under the ED HARDY Trademarks;

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

counterfeit ED HARDY products are those sold under the authorization, control, or 

supervision of Plaintiff, or are sponsored by, approved by, or otherwise connected 

with Plaintiff;

d. further infringing the ED HARDY Trademarks and damaging Plaintiff’s goodwill;

e. otherwise competing unfairly with Plaintiff in any manner;

f. 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 trademarks of Plaintiff, including the ED HARDY 

Trademarks, or any reproductions, counterfeit copies, or colorable imitations thereof;

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

Online Marketplace Accounts, the Defendant Domain Names, or any other domain 

name or online marketplace account that is being used to sell or is the means by which 

Defendants could continue to sell counterfeit ED HARDY products; and

h. operating and/or hosting websites at the Defendant Domain Names and any other domain 

names registered or operated by Defendants that are involved with the distribution,

marketing, advertising, offering for sale, or sale of any product bearing the ED HARDY 

Trademarks or any reproduction, counterfeit copy or colorable imitation thereof that are

not genuine ED HARDY products or not authorized by Plaintiff to be sold in connection 

with the ED HARDY Trademarks;

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 13 of 16 PageID #:13
14

2) That Defendants, within fourteen (14) days after service of judgment with notice of entry 

thereof upon them, be required to filed with the Court and serve upon Plaintiff a written report under 

oath setting forth in detail the manner and form in which Defendants have complied with paragraph 

1, a through h, above;

3) Entry of an Order that, at Plaintiff’s choosing, the registrant of the Defendant Domain 

Names shall be changed from the current registrant to Plaintiff, and that the domain name 

registries for the Defendant Domain Names, including, but not limited to, VeriSign, Inc., 

Neustar, Inc., Afilias Limited, CentralNic, Nominet, and the Public Interest Registry, shall 

unlock and change the registrar of record for the Defendant Domain Names to a registrar of 

Plaintiff’s selection, and that the domain name registrars take any steps necessary to transfer the 

Defendant Domain Names to a registrar of Plaintiff’s selection; or that the same domain name 

registries shall disable the Defendant Domain Names and make them inactive and untransferable;

4) Entry of an Order that, upon Plaintiff’s request, those in privity with Defendants and 

those with notice of the injunction, including any online marketplaces such as iOffer and Alibaba 

Group Holding Ltd., Alipay and any related Alibaba entities (collectively, “Alibaba”), DHgate, 

eBay, PayPal social media platforms, Facebook, YouTube, LinkedIn, Twitter, Internet search 

engines such as Google, Bing and Yahoo, web hosts for the Defendant Domain Names, and 

domain name registrars, shall:

a. disable and cease providing services for any accounts through which Defendants 

engage in the sale of counterfeit ED HARDY products using the ED HARDY 

Trademarks, including any accounts associated with the Defendants listed in 

Schedule A;

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 14 of 16 PageID #:14
15

b. disable and cease displaying any advertisements used by or associated with 

Defendants in connection with the sale of counterfeit ED HARDY products using the 

ED HARDY Trademarks; and

c. take all steps necessary to prevent links to the Defendant Domain Names identified in 

Schedule A from displaying in search results, including, but not limited to, removing 

links to the Defendant Domain Names from any search index;

5) That Defendants account for and pay to Plaintiff all profits realized by Defendants by 

reason of Defendants’ unlawful acts herein alleged, and that the amount of damages for 

infringement of the ED HARDY Trademarks be increased by a sum not exceeding three times 

the amount thereof as provided by 15 U.S.C. § 1117;

6) In the alternative, that Plaintiff be awarded statutory damages pursuant to 15 U.S.C. § 

1117(c) of not less than $1,000 and not more than $2,000,000 for each and every use of the ED 

HARDY Trademarks;

7) That Plaintiff be awarded its reasonable attorneys’ fees and costs; and

8) Award any and all other relief that this Court deems just and proper.

Respectfully submitted,

Dated: August 19, 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

HARDY WAY, LLC

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 15 of 16 PageID #:15
16

CERTIFICATE OF SERVICE

The undersigned attorney hereby certifies that a true and correct copy of the foregoing 

Complaint 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 August 19, 2020.

s/Michael A. Hierl

Case: 1:20-cv-04854 Document #: 1 Filed: 08/19/20 Page 16 of 16 PageID #:16