2024-cv-22212

COMPLAINT against The Individuals, Corporations, Limited Liability Companies, and Unincorporated Associiations Identified on Schedule A to the Complaint. Filing fees $ 405.00 receipt number AFLSDC-17591959, filed by Run-Tiger LLC d/b/a Run Chicken.

Exhibit 1 - Copyrights

Exhibit 2 - Trademarks

(Exhibit 3 - Schedule A Slip Sheet)

Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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.

FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE (Copy of AO Form, Complaint and Exhibits 1, 2, and 3 sent).

Complaint

Exhibit 1

Exhibit 2

(Exhibit 3) (ebz)

Clerk's Notice to Filer re: Electronic Case. No Civil Cover Sheet. Filer is instructed to file a Notice (Other) with the Civil Cover Sheet attached within 24 hours of the notice.

NOTICE of Filing Civil Cover Sheet by RUN-TIGER LLC re 1 Complaint

AMENDED COMPLAINT against The Individuals, Corporations, Limited Liability Companies, and Unincorporated Associiations Identified on Schedule A to the Complaint, filed by RUN-TIGER LLC.

(Exhibit Copyright Registration Certificates)

Certificate of Other Affiliates/Corporate Disclosure Statement - NONE disclosed by RUN-TIGER LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by RUN-TIGER LLC.

(Text of Proposed Order)

SYSTEM ENTRY - Docket Entry 9 [motion] restricted/sealed until further notice. (1857863)

SYSTEM ENTRY - Docket Entry 10 [motion] restricted/sealed until further notice. (1857863)

PAPERLESS ORDER granting 8 Motion to Seal. Schedule A to Plaintiff's Amended Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge Darrin P. Gayles (hs01)

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (1857863)

Order

PAPERLESS ORDER. On or before September 4, 2024, Plaintiff must (1) move to unseal Schedule A and (2) add all of the Defendants as parties through CM-ECF. The Clerk of Court is directed to CLOSE this case for administrative purposes pending service on the Defendants. Signed by Judge Darrin P. Gayles (hs01)

PAPERLESS Order Setting Hearing on Plaintiff's Motion for Preliminary Injunction on September 9, 2024, at 1:30 p.m. in the Miami Division before Judge Darrin P. Gayles at the Wilkie D. Ferguson Jr. U.S. Courthouse, 400 North Miami Avenue, Courtroom 11-1, Miami, Florida. Signed by Judge Darrin P. Gayles (hs01)

NOTICE of Filing Proposed Summons(es) in Compliance with the Court's Sealed Order Granting Plaintiff's Ex Parte Motion for Entry of Temporary Restraining Order [DE 13] by RUN-TIGER LLC

Summon(s)

Summons Issued as to The Individuals, Corporations, Limited Liability Companies, and Unincorporated Associiations Identified on Schedule A to the Complaint.

Plaintiff's MOTION for Extension of Time to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on its Motion for Preliminary Injunction, Extend the Briefing Deadlines, and Extend the Deadline to Unseal Case and Add Schedule A Defendants as Parties re 15 Administrative Order, 16 Order Setting/Resetting/Cancelling Hearing, by RUN-TIGER LLC. Responses due by 9/17/2024.

Affidavit Declaration of Nicole Fundora ISO Motion to Extend TRO and Reschedule PI Hearing

(Text of Proposed Order)

PAPERLESS ORDER granting 19 Plaintiff's Motion to Extend Ex Parte Temporary Restraining Order, Reschedule Hearing on Its Motion for Preliminary Injunction, Extend the Briefing Deadlines, and Extend the Deadline to Unseal Case and Add Schedule A Defendants as Parties. The September 9, 2024, hearing on Plaintiff's request for a preliminary injunction is rescheduled for September 23, 2024, at 9:30 a.m. Any response or opposition to Plaintiff's Motion for Preliminary Injunction must be filed with the Court and served on Plaintiff's counsel by noon on September 18, 2024. The Court finds good cause to extend the Temporary Restraining Order until the hearing on September 23, 2024. Upon expiration of the Temporary Restraining Order, Plaintiff shall move to unseal this case and add all Schedule A Defendants as Parties through CM-ECF. Signed by Judge Darrin P. Gayles (hs01)

PAPERLESS Order. Preliminary Injunction Hearing reset for September 23, 2024, at 9:30 a.m. in Miami Division before Judge Darrin P. Gayles. Signed by Judge Darrin P. Gayles (hs01)

NOTICE of Attorney Appearance by Leigh Benjamin Salomon on behalf of RUN-TIGER LLC. Attorney Leigh Benjamin Salomon added to party RUN-TIGER LLC(pty:pla).

Clerks Receipt for deposit into the registry (Bond) per order of the court (DE#13) received on 9/6/2024 in the amount of $ 10,000.00, receipt number FLS291632.

Order

NOTICE of Attorney Appearance by Jianyin Liu on behalf of ZX-JIELI. Attorney Jianyin Liu added to party ZX-JIELI(pty:dft).

NOTICE of Attorney Appearance by Jianyin Liu on behalf of smatfarm. Attorney Jianyin Liu added to party smatfarm(pty:dft).

NOTICE of Attorney Appearance by Robert George Keefe on behalf of RUN-TIGER LLC. Attorney Robert George Keefe added to party RUN-TIGER LLC(pty:pla).

CERTIFICATE OF SERVICE by RUN-TIGER LLC

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): Curiosity Tap (1), Danbirdn (2), Divine Luxury Gifts (3), Feida-store (4), Fuzzy-Bird (5), GIFANK (6), Guanyanyi (7), hao bao cheng (8), Htank (9), KIDNEYTON (10), Luoqiuhong store (11), MR QLI (12), OTYYWD (13), Smatfarm (14), WenJiuKeJi (15), ZX-JIELI (16), Jiujiang Anheze Trading Co., Ltd. (17) and Peng dou (18).

NOTICE of Voluntary Dismissal of Certain Defendant No. 7 (Guanyanyi) by RUN-TIGER LLC

PAPERLESS ORDER dismissing action without prejudice as to Defendant Guanyanyi pursuant to [30] Plaintiff's Notice of Voluntary Dismissal of Certain Defendant. Signed by Judge Darrin P. Gayles (hs01)

NOTICE of Filing (Proposed) Order Granting Plaintiff's Motion for Preliminary Injunction by RUN-TIGER LLC

Text of Proposed Order Granting Plaintiff's Motion for Preliminary Injuncti

Plaintiff's MOTION to Unseal Case by RUN-TIGER LLC. Responses due by 10/7/2024.

Text of Proposed Order Granting Motion to Unseal

PRELIMINARY INJUNCTION Signed by Judge Darrin P. Gayles on 9/24/2024. See attached document for full details. (hs01)

PAPERLESS ORDER granting 33 Plaintiff's Motion to Unseal. The Clerk is directed to unseal all docket entries in this case. Signed by Judge Darrin P. Gayles on 9/24/2024. (hs01)

MOTION for Clerk's Entry of Default as to Curiosity Tap (1), Danbirdn (2), Divine Luxury Gifts (3), Feida-store (4), Fuzzy-Bird (5), GIFANK (6), Htank (9), Jiujiang Anheze Trading Co., Ltd. (17), KIDNEYTON (10), Luoqiuhong store (11), MR QLI (12), OTYYWD (13), Peng dou (18), Smatfarm (14), WenJiuKeJi (15), ZX-JIELI, ZX-JIELI (16), hao bao cheng (8), smatfarm by RUN-TIGER LLC.

Affidavit Declaration of Nicole Fundora ISO Request for Entry of Clerk's De

MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, by ZX-JIELI, ZX-JIELI (16), smatfarm. Attorney Jianyin Liu added to party ZX-JIELI (16)(pty:dft).

Clerk's Entry of Default as to Curiosity Tap (1), Danbirdn (2), Divine Luxury Gifts (3), Feida-store (4), Fuzzy-Bird (5), GIFANK (6), Htank (9), KIDNEYTON (10), Luoqiuhong store (11), MR QLI (12), OTYYWD (13), Smatfarm (14), WenJiuKeJi (15), ZX-JIELI, ZX-JIELI (16), hao bao cheng (8), smatfarm - Motions Terminated: [36] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 10/8/2024.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, 37 MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by Smatfarm (14), ZX-JIELI, ZX-JIELI (16). Attorney Jianyin Liu added to party Smatfarm (14)(pty:dft).

PAPERLESS ORDER granting 38 Motion for Extension of Time. Defendants ZX-JIELI and Smatfarm shall respond to the Amended Complaint on or before October 12, 2024. Signed by Judge Darrin P. Gayles on 10/8/2024. (hs01)

ANSWER and Affirmative Defenses to Complaint with Jury Demand and Amended Complaint [DE 6] by ZX-JIELI, ZX-JIELI (16), smatfarm.

MOTION for Judgment on the Pleadings by ZX-JIELI, ZX-JIELI (16), smatfarm.

Exhibit A- 016 Utility Patent

NOTICE of Attorney Appearance by Jianyin Liu on behalf of GIFANK (6). Attorney Jianyin Liu added to party GIFANK (6)(pty:dft).

MOTION to Vacate [40] Clerk's Entry/Non-Entry of Default, by GIFANK (6). Responses due by 10/29/2024.

Affidavit Deng Decl.

PAPERLESS ORDER denying 44 Motion to Vacate Default and File a Response to Complaint. Defendant has failed to fully comply with S.D. Fla. L.R. 7.1(a)(3). Counsel shall identify with specificity the reasonable efforts to confer (including the date, time, and manner of each effort). The Motion is denied without prejudice. Signed by Judge Darrin P. Gayles on 10/16/2024. (hs01)

Second MOTION to Vacate 40 Clerk's Entry/Non-Entry of Default, by GIFANK (6). Responses due by 10/30/2024.

(Affidavit Deng Dec.)

NOTICE of Voluntary Dismissal of Certain Defendants Nos. 4 (Feida-store) and 11 (Luoqiuhong store) by RUN-TIGER LLC

NOTICE of Voluntary Dismissal as to Certain Defendant Only by RUN-TIGER LLC

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by RUN-TIGER LLC.

Affidavit Declaration of Nicole Fundora ISO Motion for Entry of Final Default Judgment

Text of Proposed Order

(Text of Proposed Order)

NOTICE of Voluntary Dismissal of Certain Defendants No. 9 (Htank) and 18 (Pengdu) by RUN-TIGER LLC

RESPONSE in Opposition re 42 MOTION for Judgment on the Pleadings filed by RUN-TIGER LLC. Replies due by 11/1/2024.

(Exhibit Emails to opposing counsel)

REPLY to Response to Motion re 42 MOTION for Judgment on the Pleadings filed by ZX-JIELI, ZX-JIELI (16), smatfarm.

NOTICE of Voluntary Dismissal as to Certain Defendant Only by RUN-TIGER LLC

NOTICE of Withdrawing Motion for Judgment on Pleading[ [DE 42] by Smatfarm (14), ZX-JIELI, ZX-JIELI (16), smatfarm re [42] MOTION for Judgment on the Pleadings

PAPERLESS Order Dismissing Defendant GIFANK without prejudice pursuant to 53 Plaintiff's Notice of Voluntary Dismissal of Certain Defendant. Signed by Judge Darrin P. Gayles on 12/18/2024. (hs01)

PAPERLESS ORDER denying as moot 46 Second Motion to Vacate Default and File a Response to the Complaint in light of Plaintiff's voluntary dismissal of Defendant GIFANK. Signed by Judge Darrin P. Gayles on 12/18/2024. (hs01)

NOTICE of Voluntary Dismissal of Defendants Nos. 14 (Smatfarm) and 16 (ZX-JIELI) by RUN-TIGER LLC

PAPERLESS ORDER. Pursuant to Plaintiff's Notices of Voluntary Dismissal of Certain Defendants [47] [48] [50] [57], Defendants 4, 9, 11, 14, 16, 17, and 18 on Schedule A to Plaintiff's Amended Complaint, [12], are dismissed without prejudice. Signed by Judge Darrin P. Gayles on 8/4/2025. (hs01)

ORDER granting [49] Motion for Entry of Default Final Judgment. Signed by Judge Darrin P. Gayles on 8/4/2025. See attached document for full details. (hs01)

DEFAULT FINAL JUDGMENT. Signed by Judge Darrin P. Gayles on 8/4/2025. See attached document for full details. (hs01)

DISBURSEMENT ORDER. Signed by Judge Darrin P. Gayles on 8/4/2025. See attached document for full details. (hs01)