2022-cv-00456

COMPLAINT filed by Rarog j.d.o.o.; Filing fee $ 402, receipt number 0752-19093183.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Rarog j.d.o.o. Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yi Bu

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Rarog j.d.o.o. by Adam Grodman

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

SEALED DOCUMENT by Plaintiff Rarog j.d.o.o. Amended Schedule A to Complaint (1)

SEALED MOTION by Plaintiff Rarog j.d.o.o. for Leave to File Under Seal

MOTION by Plaintiff Rarog j.d.o.o. for leave to file under seal

MOTION by Plaintiff Rarog j.d.o.o. for leave to file excess pages

MEMORANDUM in Support of [12] Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, Declaration of Keith A. Vogt

Declaration of Sanda Krstulovi

Exhibit 1, Declaration of Sanda Krstulovi

SEALED EXHIBIT by Plaintiff Rarog j.d.o.o. Sealed Exhibit 2, Declaration of Sanda Krstulovi regarding memorandum in support of motion, [13]

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motions 9 10 11 to seal and file extra pages are granted (the sealing is justified, for now, given the asset-restraint goal). But the motion 12 for TRO and other relief is entered and continued. The Plaintiff shall file a supplement, by 02/07/2022, that specifically matches the allegedly infringing images in R. 14 to the specific copyright in R. 13-4. The supplemental filing may be filed under seal, for now. To track the case only (no appearance is required, the case will not be called), a tracking status hearing is set for 02/18/2022 at 8:30 a.m. Mailed notice

SEALED DOCUMENT by Plaintiff Rarog j.d.o.o. Supplement of infringing images in R. 14 to the specific copyright in R. 13-4

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion 12 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 Court notes that the supplemental filing, R. 17, specifies the allegedly infringed copyright. By 02/10/2022, 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). To track the case only (no appearance is required, the case will not be called), a status hearing is set for 02/18/2022 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 02/11/2022. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 02/04/2022. Emailed Counsel for the Plaintiff 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 02/04/2022. Emailed notice

MOTION by Plaintiff Rarog j.d.o.o. for preliminary injunction

SUMMONS Returned Executed by Rarog j.d.o.o. as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 2/10/2022, answer due 3/3/2022.

Declaration of Service

MINUTE entry before the Honorable Edmond E. Chang: In light of the continued applicability of the facts that justified the entry of the TRO, the motion for preliminary injunction 21 is granted. The answer deadline appears to be 03/03/2022. R. 23. The tracking status hearing of 02/18/2022 is reset to 03/18/2022 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 03/08/2022. If no answer has been filed, then the Defendants are deemed to be in default, and the Plaintiff shall file a default judgment motion by 03/08/2022 instead of the status report. Emailed notice

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

SURETY BOND in the amount of $ 10,000.00 posted by Rarog j.d.o.o. (Document not scanned).

MOTION by Plaintiff Rarog j.d.o.o. for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Rarog j.d.o.o. in support of motion for default judgment 27

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MEMORANDUM by Rarog j.d.o.o. in support of motion for default judgment 27 [CORRECTED] MEMORANDUM by Rarog j.d.o.o. in support of motion for default judgment 27

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Edmond E. Chang: The motion for default judgment and permanent injunction 27 is granted in part. As explained in the judgment order, statutory damages are awarded in the amount of $15,000 as to each Defendant (rather than the $50,000 award requested by the Plaintiff). A separate AO-450 judgment shall be entered, including a permanent injunction in light of the willfulness established by the default. The tracking status hearing of 03/18/2022 is vacated, as are all other litigation deadlines. Civil case terminated. Emailed notice

FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 03/08/2022. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 03/08/2022. Emailed notice