2025-cv-60369

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Filing fees $ 405.00 receipt number AFLSDC-18232787, filed by Kids Magic LLC.

Exhibit 1 to Complaint (Copyright Registrations)

(Complaint) (ksr)

(Text of Proposed Order)

Declaration of Valeria Munoz

Client Declaration in Support of Temporary Restraining Order

(Schedule A) Modified to Unseal Entry on 4/10/2025 PER DE#32 (cds)

Declaration of Valeria Munoz in Support of Motion to Extend Temporary Restraining Order

(Proposed Summons)

Declaration of V. Munoz in Support of Plaintiff's Second Motion to Extend Ex Parte Temporary Restraining Order

Certification of John M. Mueller

(Text of Proposed Order Granting Unopposed Motion to Unseal)

(Text of Proposed Order Granting Plaintiff's Motion for Preliminary Injunction)

Declaration of Valeria Munoz

(Declaration of Valeria Munoz in Support of Request for Entry of Clerk's Default)

(Text of Proposed Order Granting Joint Motion for Extension of Time)

(Declaration of Valeria Munoz in Support of Request for Entry of Clerk's Default)

Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment

(Proposed Disbursement Order)

Clerks Notice of Judge Assignment to Judge Robin L. Rosenberg and Magistrate Judge Panayotta D. Augustin-Birch. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Panayotta Augustin-Birch is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

(Civil Cover Sheet)

Exhibit 1 - Combating Trafficking in Counterfeit and Pirated Goods

Exhibit 1 to Client Declaration - Copyright Registrations

(Text of Proposed Order in Support of Motion to Extend Temporary Restraining Order)

(Text of Proposed Order Granting Plaintiff's Second Motion to Extend Ex Parte Temporary Restraining Order)

(Text of Proposed Order)

(Exhibit 1 - Service Email)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 1 of 15)

FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE

(Text of Proposed Order) Modified to Unseal Entry on 4/10/2025 PER DE#32 (cds)

Exhibit 2 to Client Declaration (Part 1 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 2 of 15)

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Kids Magic LLC identifying Corporate Parent Kids Magic Limited, Other Affiliate Circles Magic LLC for Kids Magic LLC

Exhibit 2 to Client Declaration (Part 2 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 3 of 15)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Kids Magic LLC.

Exhibit 2 to Client Declaration (Part 3 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 4 of 15)

Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support by Kids Magic LLC.

Exhibit 2 to Client Declaration (Part 4 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 5 of 15)

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery by Kids Magic LLC.

Exhibit 2 to Client Declaration (Part 5 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 6 of 15)

ORDER OF REFERENCE TO MAGISTRATE JUDGE AND ORDER OF COURT-MANDATED REQUIREMENTS ON SERVICE, DEFAULTS, AND JOINT SCHEDULING REPORTS, REFERRING CASE to Magistrate Judge Panayotta D. Augustin-Birch for discovery matters. Signed by Judge Robin L. Rosenberg on 2/28/2025. See attached document for full details.

Exhibit 2 to Client Declaration (Part 6 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 7 of 15)

ORDER Granting 5 Motion to Seal. Schedule A to Plaintiff's Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge Robin L. Rosenberg on 3/5/2025. See attached document for full details.

Exhibit 2 to Client Declaration (Part 7 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 8 of 15)

ORDER Granting 6 PLAINTIFF'S MOTION TO AUTHORIZE ALTERNATE SERVICE OF PROCESS ON DEFENDANTS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(f)(3). Signed by Judge Robin L. Rosenberg on 3/5/2025. See attached document for full details. (cds) Modified to Unseal Entry on 4/10/2025 PER DE#32

Exhibit 2 to Client Declaration (Part 8 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 9 of 15)

ORDER Granting 7 PLAINTIFF'S EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER AND SETTING HEARING. Preliminary Hearing set for 3/19/2025 01:30 PM via Zoom before Judge Robin L. Rosenberg. Signed by Judge Robin L. Rosenberg on 3/5/2025. See attached document for full details. (cds) Modified to Unseal Entry on 4/10/2025 PER DE#32

Exhibit 2 to Client Declaration (Part 9 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 10 of 15)

Sealed Document Notice of Filing Schedule A Under Seal re DE# 9 Order on Motion to Seal, by Kids Magic LLC.

Exhibit 2 to Client Declaration (Part 10 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 11 of 15)

Plaintiff's MOTION for Extension of Time for Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, and Extend the Briefing Deadlines by Kids Magic LLC. Responses due by 3/27/2025.

Exhibit 2 to Client Declaration (Part 11 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 12 of 15)

NOTICE of Filing Proposed Summons(es) by Kids Magic LLC

Exhibit 2 to Client Declaration (Part 12 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 13 of 15)

Summons Issued as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A.

Exhibit 2 to Client Declaration (Part 13 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 14 of 15)

PAPERLESS ORDER granting in part Plaintiff's 13 Motion. The hearing on Plaintiff's Motion for Preliminary Injunction shall be moved to April 11, 2025, at 1 p.m. Eastern; the Zoom information will remain the same as in the Court's Order Setting Hearing at docket entry 11, page 10. Defendant's deadline to respond to Plaintiff's Motion is April 9, 2025. Plaintiff's deadline to reply is April 10, 2025. The 11 temporary restraining order shall be EXTENDED by 14 days through March 28, 2025. Plaintiff shall file any motion to extend the temporary restraining order no later than March 28, 2025, at 12 p.m. Eastern. Signed by Judge Robin L. Rosenberg

Exhibit 2 to Client Declaration (Part 14 of 21)

Exhibit 1 to the Declaration of Valeria Munoz in Support of Motion for Entry of Final Default Judgment (Part 15 of 15)

Reset Deadlines Per DE#16. Motions due by 3/28/2025. Responses due by 4/9/2025. Replies due by 4/10/2025. (Text entry; no document attached.)

Deadline(s)/Hearing(s) terminated.,Reset Hearings (Preliminary Injunction Hearing reset for 5/13/2025 02:30 PM in West Palm Beach Division before Judge Robin L. Rosenberg.) (Text entry; no document attached.)

Reset Deadlines Per DE 44 Joint Scheduling Report due by 4/28/2025 (Text entry; no document attached.)

Hearing terminated. Per DE 51. (Text entry; no document attached.)

Clerks Receipt for bond for TRO per order of the court (DE#11) sealed received on 3/25/2025 in the amount of $ 10,000.00, receipt number FLS300353.

Exhibit 2 to Client Declaration (Part 15 of 21)

Text of Proposed Order Granting Motion for Entry of Final Default Judgment

Cash BOND / TRO in the amount of $10,000.00 receipt # 300353 posted by Kids Magic LLC Approved by Judge Robin L. Rosenberg

Exhibit 2 to Client Declaration (Part 16 of 21)

(Text of Proposed Order on Final Default Judgment and Permanent Injunction)

Second MOTION for Extension of Time for Ex Parte Temporary Restraining Order re 16 Order on Motion for Extension of Time, by Kids Magic LLC. Responses due by 4/10/2025.

Exhibit 2 to Client Declaration (Part 17 of 21)

PAPERLESS ORDER granting Plaintiff's 19 Second Motion for Extension of Time for Ex Parte Temporary Restraining Order. The 16 temporary restraining order shall remain in effect through the conclusion of the preliminary injunction hearing on April 11, 2025. See DE 11 at 10. Signed by Judge Robin L. Rosenberg

Exhibit 2 to Client Declaration (Part 18 of 21)

NOTICE of Voluntary Dismissal of Defendants Nos. 54 (3adgstore), 87 (SYQSHOP), and 91 (zhangchengguifugui) by Kids Magic LLC

Exhibit 2 to Client Declaration (Part 19 of 21)

NOTICE of Voluntary Dismissal of Defendants Nos. 11 (Vanshion Home & Living) and 79 (Jinhe Maoyi) by Kids Magic LLC

Exhibit 2 to Client Declaration (Part 20 of 21)

NOTICE of Voluntary Dismissal of Defendants Nos. 59 (AUKELE), 70 (YJYKBSHOP), and 72 (YUKIFIT) by Kids Magic LLC

Exhibit 2 to Client Declaration (Part 21 of 21)

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): Ai Yu Li, balloon party, dwqdxcvv, Gemapaty, HAOLV, HLJX Toys, JINC2, Summer day, tingshivv, torelcatu, WWWFC, Xiya balloon, Yaree2, YWFuYu, Lanxi Zhishang Electronic Commerce Co., Ltd., Shenzhen Tuoyi Electronic Commerce Co., Ltd., Wuhan Tknow Toys Co., Ltd., Xinxiang Dixini E- Commerce Co., Ltd., Yiwu Dun Shan Trading Co., Ltd., Yiwu Feiyue Festive Products Co., Ltd., Yiwu Haolv Toys Co., Ltd., Yiwu Yuyue Trading Co., Ltd., 3 Yuan Store, 6682663 Store, 812919634 Store, An Interesting Shop Store, Animation Plush Store, Balloons party supplies Store, Bolatu0810 Store, Bolatu0812 Store, BOOKFONG Official Store, Celebrate Party Balloons Store, Chaoyu Toy Store, Charm Party Store, Comfort Cushion Covers Available Store, Ananle-Joy, daiyalishangmao, genmaiwansui, Hechengmaoyi, KatchOnTM Store, KatchOn Store, kawaii-store, Linmin1988, Lujind, NSSTAR, Pevoris Foe Pulaile Store, QiQiSen, xiangge-shop, YiYou., YYTCST, ZAKSLSEON, zhijiangshigedunshuo youxiangongsi, 53shaf42 (StoreMiyuki), kyrylo_dranovych (Plush and Leather WORKSHOP), luckymall (Nymbba), MONSTOY Support, BRIDE PARTY, doudoua, Hua Qian Party, KKRECOME, Party in Seattle, SP Decoration Party Supplies, ThemooninYiwuCity, xiaopai party, YAREE, Yiwu Dieyu Ecommerce Co Ltd, yuanmua, chaoyz258, DengChengLin, Dyue, FENPENG, HETUIWLO, JEZIZAN, mengsitong, NanYuShangMaoYouXianGongSi, ngzhouxiongzhensha ngm, PanrunzePlus, Shan Gua Store, shenzhenshichuangzhiboyikeji, shenzhenshitianyifeif andianzikejiyouxiang ongsi, xiaoyinlinshangmaoy ouxian, XinJunWeiKeJi and YCT AUTO.

(Text of Proposed Order) Modified to Unseal Entry on 4/10/2025 PER DE#32 (cds)

SUMMONS (Affidavit) Returned Executed on 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Kids Magic LLC. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A served on 4/7/2025, response/answer due 4/28/2025.

NOTICE of Attorney Appearance by Christa Cowart Turner on behalf of KatchOnTM Store, KatchOn Store. Attorney Christa Cowart Turner added to party, Attorney Christa Cowart Turner added to party.

MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing for John M. Mueller. Filing Fee $ 250.00 Receipt # AFLSDC-18351243 by KatchOnTM Store, KatchOn Store. Responses due by 4/22/2025.

PAPERLESS ORDER GRANTING 27 Motion to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing. John M. Mueller, Esq. may appear and participate in this action pro hac vice on behalf of Defendant Rosenza International Trading LLC d/b/a KatchOnTM Store and KatchOnTM Store. The Clerk of Court shall provide electronic notification of all electronic filings to Attorney Mueller at jmueller@bakerlaw.com. Signed by Magistrate Judge Panayotta D. Augustin-Birch on 4/9/2025.

NOTICE of Voluntary Dismissal of Defendants Nos. 2 (balloon party), 5 (HAOLV), 7 (JINC2), 13 (Xiya balloon), 14 (Yaree2), 64 (Party in Seattle), and 68 (YAREE) by Kids Magic LLC

Unopposed MOTION to Unseal by Kids Magic LLC.

Defendant's RESPONSE IN OPPOSITION TO MOTION FOR PRELIMINARY INJUNCTION (DKT. 7) by KatchOnTM Store, KatchOn Store.

PAPERLESS ORDER granting Plaintiff's 30 Unopposed Motion to Unseal. The Clerk of Court is directed to unseal all docket entries in this case and return those portions of the file to the public records. Signed by Judge Robin L. Rosenberg

CLERK'S NOTICE of Compliance (All Docket Entries in this Case have Been Unsealed) re 32 PAPERLESS ORDER.

ORDER GRANTING IN PART BY DEFAULT 7 PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION AND RESCHEDULING THE PRELIMINARY INJUNCTION HEARING, (Preliminary Injunction Hearing reset for 5/15/2025 10:00 AM before Judge Robin L. Rosenberg.) Signed by Judge Robin L. Rosenberg on 4/10/2025. See attached document for full details.

Plaintiff's NOTICE of Filing [Proposed] Order Granting Plaintiff's Motion for Preliminary Injunction by Kids Magic LLC

Plaintiff's REPLY to Response to Motion re 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery. re 31 Defendants' Opposition to Motion for Preliminary Injunction filed by Kids Magic LLC.

PRELIMINARY INJUNCTION ORDER AS TO THE DEFENDANTS IDENTIFIED ON SCHEDULE A TO THE ORDER. Signed by Judge Robin L. Rosenberg. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendants Nos. 15 (YWFuYu) and 50 (YiYou.) by Kids Magic LLC

PAPERLESS ORDER rescheduling the 34 preliminary injunction hearing for Tuesday, May 13, 2025, at 2:30 PM Eastern. Signed by Judge Robin L. Rosenberg

NOTICE of Voluntary Dismissal of Defendants Nos. 56 (kyrylo_dranovych) and 58 (MONSTOY Support) by Kids Magic LLC

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A by Kids Magic LLC.

Joint MOTION for Extension of Time of All Current Pending Dates, Including the Deadline to File the Joint Scheduling Report by Kids Magic LLC. Responses due by 5/6/2025.

(Restricted- Error in filing by clerk) Signed by DEPUTY CLERK on 4/23/2025.

PAPERLESS ORDER granting 42 Motion for Extension of Time. The Parties are directed to file a Joint Scheduling Order by April 28, 2025. Signed by Judge Robin L. Rosenberg

Clerk's Notice of Docket Correction re 43 Clerk's Entry/Non-Entry of Default. Correction Other. Clerk's Entry/Non-Entry of Default. in error RE:Per Attorney, DE 8 instruction required early filing.

Clerk's Non-Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A. Reason: Summons (Affidavit) Returned Executed OR Waiver of Service Executed - has NOT been entered on docket Signed by DEPUTY CLERK on 4/23/2025.

NOTICE of Voluntary Dismissal of Defendants Nos. 43 (kawaii-store), 78 (JEZIZAN), and 89 (XinJunWeiKeJi) by Kids Magic LLC

NOTICE of Settlement of Defendants Nos. 41 (KatchOnTM Store) and 42 (KatchOnTM Store) by Kids Magic LLC

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A by Kids Magic LLC.

Clerk's Entry of Default as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A of DE 49 - Motions Terminated: 49 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/1/2025.

PAPERLESS ORDER canceling the May 13, 2025 39 preliminary injunction hearing in light of the 48 Notice of Settlement. Signed by Judge Robin L. Rosenberg

NOTICE of Voluntary Dismissal of Defendants Nos. 37 (Ananle-Joy) and 51 (YYTCST) by Kids Magic LLC

NOTICE of Voluntary Dismissal of Defendants Nos. 10 (torelcatu) and 25 (6682663 Store) by Kids Magic LLC

Plaintiff's MOTION for Default Judgment by Kids Magic LLC.

MOTION to Withdraw Document 31 Response/Reply (Other) by KatchOnTM Store, KatchOn Store. Responses due by 5/23/2025.

PAPERLESS ORDER granting Defendant Rosenza International Trading LLC's 55 Motion to Withdraw Response in light of the parties' 48 Notice of Settlement. Signed by Judge Robin L. Rosenberg

NOTICE of Voluntary Dismissal of Defendants Nos. 41 (KatchOnTM Store) and 42 (KatchOnTM Store) by Kids Magic LLC

NOTICE of Voluntary Dismissal of Defendant No. 47 (Pevoris Foe Pulaile Store) by Kids Magic LLC

ORDER ON MOTION FOR ENTRY OF FINAL DEFAULT JUDGMENT, DEFAULT JUDGMENT in favor of Kids Magic LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A, herein. (Responses due by 5/19/2025.) Signed by Judge Robin L. Rosenberg on 5/13/2025. See attached document for full details.

SATISFACTION OF JUDGMENT as to Defendants Nos. 6 (HLJX Toys) and 12 (WWWFC) by Kids Magic LLC

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Kids Magic LLC against The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A, PERMANENT INJUNCTION Closing Case. Signed by Judge Robin L. Rosenberg on 5/21/2025. See attached document for full details.

FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE

Plaintiff's MOTION for Disbursement of Funds by Kids Magic LLC.

DISBURSEMENT ORDER granting 63 Motion for Disbursement of Funds to Boies Schiller Flexner LLP in the amount of $10,000.00. Signed by Judge Robin L. Rosenberg on 5/27/2025. See attached document for full details.

ANSWER and Affirmative Defenses to Complaint by NSSTAR. Attorney Alan Mensa-Wilmot added to party.

Joint STIPULATION of Dismissal of Defendant No. 46 by Kids Magic LLC Modified Text on 6/25/2025