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Counterfeit Product Cases

Plaintiffs in cases alleging counterfeit products and joining many defendants should use the form proposed orders linked below to assist the Court in reviewing motions for: (1) temporary restraining orders; (2) preliminary injunctions; and (3) default judgments. Plaintiffs should create a redline comparison of their proposed order against the relevant form and attach it as an exhibit to their motion. A proposed order's conformity with the form does not imply that the associated motion will be granted. But plaintiffs should be prepared to explain any differences.

In any motion for temporary restraining order filed with the Court, Plaintiffs must state whether they have previously sued any of the defendants regarding the product at issue in another case brought before another federal judge and if so, identify which judge, the case number, and the disposition of that case (e.g., voluntary dismissal; dismissal by the court without prejudice).

Judge Durkin will presumptively require a bond of $1,000 per defendant. Plaintiffs should inform the Court of any circumstances that make such a bond inappropriate.

Form of Proposed Temporary Restraining Order
Form of Preliminary Injunction
Form of Default Judgment


Note: The court does not control nor can it guarantee the accuracy, relevance, timeliness, or completeness of this information. Neither is it intended to endorse any view expressed nor reflect its importance by inclusion in this site.
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