2022-cv-00058

COMPLAINT filed by Ilustrata Servicos Design, Ltda.; Filing fee $ 402, receipt number 0752-19023008.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Ilustrata Servicos Design, Ltda. Amended Schedule A 2 to Complaint 1

MOTION by Plaintiff Ilustrata Servicos Design, Ltda. for leave to file [Certain] Documents Under Seal

MOTION by Plaintiff Ilustrata Servicos Design, Ltda. for leave to file excess pages

MEMORANDUM In Support of 11 Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, Declaration of Keith Vogt

Declaration of David Faraum

Exhibit 1, Declaration of David Faraum

SEALED EXHIBIT by Plaintiff Ilustrata Servicos Design, Ltda. Sealed Exhibit 2 to the Declaration of David Faraum regarding memorandum in support of motion 12

MAILED Copyright report to Registrar, Washington DC.

NOTICE by Keith A. Vogt of Change of Address

NOTICE by Adam Grodman of Change of Address

NOTICE by Yi Bu of Change of Address

NOTICE by Yanling Jiang of Change of Address

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion 11 for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 15 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendant may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion 9 for leave to file under seal is granted in light of the asset-restraint goal. By 01/17/2022, The Plaintiff shall email a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Amended Schedule A). The Plaintiff's motion 11 for electronic service of process is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 01/26/2022 at 8:30 a.m. Because the TRO expires on 01/26/2022, the Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 01/21/2022. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 01/12/2022. Emailed notice

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

REDACTED SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 01/12/2022. Emailed notice

MOTION by Plaintiff Ilustrata Servicos Design, Ltda. for preliminary injunction

MEMORANDUM by Ilustrata Servicos Design, Ltda. in support of motion for preliminary injunction 22

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith Vogt

SUMMONS Returned Executed by Ilustrata Servicos Design, Ltda. as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 1/17/2022, answer due 2/7/2022.

Declaration of Service

MINUTE entry before the Honorable Edmond E. Chang: In light of the facts that justified the entry of the TRO, the motion to enter preliminary injunction 22 is granted. The answer deadline appears to be 02/07/2022. R. 24. The tracking status hearing of 01/26/2022 is reset to 02/25/2022 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, if the Defendant has not timely answered, then the Plaintiff shall file a motion for default judgment by 02/15/2022. Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 01/19/2022. Emailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Ilustrata Servicos Design, Ltda. (Document not imaged)

MOTION by Plaintiff Ilustrata Servicos Design, Ltda. for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Ilustrata Servicos Design, Ltda. in support of motion for default judgment 28

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 28 for default judgment is granted, although the award will be $20,000 per Defaulting Defendant, as explained in the judgment order. A permanent injunction is entered in light of the willfulness (as established by the default). A separate AO-450 judgment shall be entered. The tracking status hearing of 02/25/2022 is vacated. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 02/11/2022. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 02/11/2022. Emailed notice

MAILED copyright report to Registrar, Washington DC