2022-cv-02230

COMPLAINT filed by Tangle Inc.; Filing fee $ 402, receipt number 0752-19387933.

Exhibit 1 (IP Registrations)

(Exhibit 2 (Provisionally Filed Under Seal - Schedule A))

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Tangle Inc. by David Edward Hutchinson

SEALED EXHIBIT by Plaintiff Tangle Inc. Schedule A regarding complaint 1

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tangle Inc. Corporate Disclosure Statement

Report on the Filing or Determination of An Action Regarding A Patent or Trademark by Tangle Inc.

Report on the Filing or Determination of An Action or Appeal Regarding A Copyright by Tangle Inc.

(Schedule A to AO 121 Form)

Plaintiff's Ex Parte Motion for Leave to File Under Seal by Tangle Inc.

Plaintiff's Ex Parte Motion for Entry of A Temporary Restraining Order, Including a Temporary Injunction, A Temporary Transfer of the Defendant Internet Stores, A Temporary Asset Restraint, Expedited Discovery, and Service of Process by Email and/or Electronic Publication by Tangle Inc.

MOTION by Plaintiff Tangle Inc. for leave to file excess pages Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order

Exhibit A - Memorandum

Declaration of David Hutchinson

Exhibit 1 to David Hutchinson's Declaration

Exhibit 2 to David Hutchinson's Declaration

Exhibit 3 to David Hutchinson's Declaration

Exhibit 4 to David Hutchinson's Declaration

Exhibit 5 to David Hutchinson's Declaration

Exhibit 6 to David Hutchinson's Declaration

Declaration of Richard Zawitz

Exhibit 1 to Richard Zawitz's Declaration

(Exhibit 2 to Richard Zawitz's Declaration (to be filed filed under seal))

SEALED EXHIBIT by Plaintiff Tangle Inc. regarding MOTION by Plaintiff Tangle Inc. for leave to file excess pages Plaintiff's Ex Parte Motion for Entry of a Temporary Restraining Order 10

Exhibit 2 (Part 1 of 14)

Exhibit 2 (Part 2 of 14)

Exhibit 2 (Part 3 of 14)

Exhibit 2 (Part 4 of 14)

Exhibit 2 (Part 5 of 14)

Exhibit 2 (Part 6 of 14)

Exhibit 2 (Part 7 of 14)

Exhibit 2 (Part 8 of 14)

Exhibit 2 (Part 9 of 14)

Exhibit 2 (Part 10 of 14)

Exhibit 2 (Part 11 of 14)

Exhibit 2 (Part 12 of 14)

Exhibit 2 (Part 13 of 14)

(Exhibit 2 (Part 14 of 14))

ATTORNEY Appearance for Plaintiff Tangle Inc. by Harry Moren

ATTORNEY Appearance for Plaintiff Tangle Inc. by Christopher M. Tom

CIVIL Cover Sheet

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. (Text entry; no document attached.)

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment. (Text entry; no document attached.)

SEALED EXHIBITS by Plaintiff Tangle Inc. Declaration of Richard Zawitz (Exhibit 2) Modified on 5/6/2022.

Exhibit 2 (1 of 15)

Exhibit 2 (2 of 15)

Exhibit 2 (3 of 15)

Exhibit 2 (4 of 15)

Exhibit 2 (5 of 15)

Exhibit 2 (6 of 15)

Exhibit 2 (7 of 15)

Exhibit 2 (8 of 15)

Exhibit 2 (9 of 15)

Exhibit 2 (10 of 15)

Exhibit 2 (11 of 15)

Exhibit 2 (12 of 15)

Exhibit 2 (13 of 15)

Exhibit 2 (14 of 15)

(Exhibit 2 (15 of 15))

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff improperly filed docket entry 17 as a motion instead of exhibits. The motion is terminated and the Clerk is directed to amend the docket wording to state Exhibits. Mailed notice

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's ex parte motions for leave to file under seal 8, to exceed page limitation 10 16 and ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary transfer of the defendant internet stores, a temporary asset restraint, expedited discovery, and service of process by e-mail and electronic publication 15 are granted. Enter Sealed TRO. Telephonic status hearing set for 5/19/2022 at 9:45 a.m. The call-in number is (888) 684-8852, and the access code is 1503395. Mailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 5/5/2022. Mailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 5/9/2022. Mailed notice

BOND in the amount of $5,000.00 by Tangle Inc.

BOND in the amount of $5000.00 check, Receipt No. 4624271709, posted by Tangle Inc. (Text entry; no document attached.)

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's ex parte motion to extend Temporary Restraining Order 23 is granted. Enter Order. Telephonic status hearing set for 5/19/2022 is stricken and reset to 6/2/2022 at 9:15 a.m. The call-in number is (888) 684-8852, and the access code is 1503395. Mailed notice

ORDER ON PLAINTIFF'S EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 5/17/2022. Mailed notice

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Tangle Inc. of Defendant THE ELEVEN (99)

MEMORANDUM in Support of Plaintiff's Ex Parte Motion to Extend Temporary Restraining Order

(Declaration of Harry Moren)

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's ex parte motion to extend temporary restraining order through 6/9/2022 27 is granted. Enter Order. Telephonic hearing set for 6/2/2022 is stricken and reset for 6/7/2022 at 9:15 a.m. Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ORDER ON PLAINTIFF'S EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 5/31/2022. Mailed notice

MOTION by Plaintiff Tangle Inc. for preliminary injunction

Memo in support of Preliminary Injunction

(Declaration Declaration of David E. Hutchinson in support of Motion for Preliminary Injunction)

SUMMONS Returned Executed by Tangle Inc. as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 6/4/2022, answer due 6/27/2022.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 6/7/2022. No defendants appeared on the hearing. For the reasons stated on the record, Plaintiff's motion for entry of a preliminary injunction 31 is granted. Enter Order. Thoits Law is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at www.ilnd.uscourts.gov/instructions. Telephonic status hearing set for 7/28/2022 at 9:15 a.m. Plaintiff is directed to file a brief status report on or before 7/21/2022. Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. The Clerk is directed to unseal Plaintiff's Schedule A to the Complaint 4, Exhibit 2 to the Declaration of Richard Zawitz and the Temporary Restraining Orders 20 21. Mailed notice

PRELIMINARY INJUNCTION Order signed by the Honorable Robert W. Gettleman on 6/7/2022. Mailed notice

NOTICE of Voluntary Dismissal by Tangle Inc. of Defendants FOREVIVE (97) and funsensoryplay (112)

NEW PARTIES: (131), Free Market Co., Ltd (1), Qingdao Pretty International Trade Co., Ltd. (2), Shenzhen Chentao Toy Limited Company (3), Xinxiang Hiton Technology Co., Ltd. (4), Yiwu Huishan Electronic Technology Co., Ltd. (5), Yiwu Qiger Trade Co., Ltd.(6), 66happytoy Store (7), 777 Remote Control Toy Store (8), Ababy Store (9), Alibabas Anime Store (10), Aliplay Store (11), babytoy buyer Store (12), Bad Monkey Store (13), BaoChenyi (14), Bauble Store (15), Blocks Toy Store (16), blue babies Store (17), BroKids Official Store (18), Chase Wind Childhood Store (19), Childhood fun Store (20), Dancing.baby Store (21), DOBE toy factory Store (22), Dudufly Store (23), Educational Toy City Store (24), EFFOSOLA Store (25), Fidget Dropshipping Store (26), ForDear Kids Store (27), Fun Leisure Toy Store (28), Go GoBaby Store (29), GuluGuluToy Store (30), He Xing Kid World Store (31), Healthy & Wealthy Life Store (32), hellowe plaything Store (33), hevesrz KiKiToy Store (34), HobbiesToys Store (35), idealism Store (36), Jane home-she Store (37), JENE Dropshipping Store (38), JENEEY ONE Official Store (39), JHJXJLWJD Store (40), Keep-in Fitness Store (41), Kingot Store (42), Kitty's Toy Drop Shopping Store (43), KKtoy Store (44), LDYY Store (45), Love- Store (46), Lun Sen Store (47), lvse life Store (48), Microsmile Store (49), MM baby DD Store (50), Moruska Official Store (51), Mother's Baby Store (52), Motta Ronnie TOY Store (53), MS Toy Store (54), MUMTEAQAQ Store (55), My Sweetbaby Store (56), New Kid toy world Store (57), Novelty toy Store (58), Orstarry Oficial Store (59), Panen Global Dropshipping Store (60), Pimpimsky Child World Store (61), QLFAN Toy Official Store (62), Rainbowbaby Store (63), RC-Toy Store (64), Release pressure funny life Store (65), SHIRUI Store (66), Shop1100150312 Store (67), Shop4046058 Store (68), Shop5138078 Store (69), Shop5614357 Store (70), Shop5890326 Store (71), Shop910554234 Store (72), Shop910799007 Store (73), Shop911423320 Store (74), Shop911474050 Store (75), Shop912091019 Store (76), SIMIDADA Official Store (77), simidada Store (78), Small World 138 Store (79), SPAKOGY Store (80), stictech ltd.,baby Store (81), supstem Official Store (82), Tinytoys Store (83), TOY WHOSALE Store (84), Toy&House Store (85), TUNJILOOL Official Store (86), UainCube Booby Store (87), UFOMeet Store (88), Various toy stores Store (89), Wonder Toy Garden Store (90), Wonderful- Store (91), XF Toy Factory Store (92), Yescustom Toy Store (93), YIXUAN888 Store (94), You qu Childhood Store (95), yuluch toy Store (96), FOREVIVE (97), PAOLV11 (98), THE ELEVEN (99), Tomwell (100), Tomwell Toys (101), yichunjiamushangmaoyouxiangongsi (102), YoHey (103), yuekebaihuodian (104), dp02 (105), superiormall (106), wonopeshop (107), alpinetopline (108), ceylon_product_90 (109), fidgethands (110), flowersgrass (111), funsensoryplay (112), hayesy-collectables (113), home-essentials-uk (114), homegardentool (115), jqfe3277-uk (116), justcoolgifts (117), look_mestore98 (118), michal_store (119), more4l_18 (120), mxx624 (121), pnfproducts (122), stivemax (123), tkhan1220 (124), trainingshop (125), vegi_store (126), xbliss.fidgetsx (127), xia45133_44 (128), yongch-7947 (129), ZURU (130), Saturday Children playhouse (132), SHOME (133), SIMIDADA (134), Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138), All for all Co.Ltd (139), Fashair (140), fhyznfexs (141), GraceGift (142), liru28636 (143), Sanyuwanke (144), Satya_funny (145), thu_xj (146), Vyddr32shop (147), Wangzhenzhuing (148), wuyeyoumin (149), Xingxing star story (150), yinjinjin3656 (151), yueshuangxi3175 (152), zhangxiaoya2327 (153), zhangyaping2160 (154), zhangyue2757 (155), zhangyule3693 (156) and zhanwanjuan2904 (157) added to case caption. (Text entry; no document attached.)

ATTORNEY Appearance for Plaintiff Tangle Inc. by Nathan Daniel Monroe-yavneh

STATUS Report by Tangle Inc.

MINUTE entry before the Honorable Robert W. Gettleman: On review of the Status Report 37, telephonic status hearing set for 7/28/2022 is stricken and reset to 8/24/2022 at 9:15 a.m. Plaintiff is directed to file a brief status report on or before 8/17/2022. Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ATTORNEY Appearance for Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) by David M. Airan (Jingdong Ecommerce (Trade) Hong Kong Corporation Limited)

ATTORNEY Appearance for Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) by Nicole E. Kopinski (Jingdong Ecommerce (Trade) Hong Kong Corporation Limited)

MOTION by Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) for extension of time - AGREED Motion to Extend Deadlines Regarding Joybuy, Joybuy Express, Joybuy Fashion, and Joybuy Selection

MINUTE entry before the Honorable Robert W. Gettleman: Agreed Motion to Extend Deadlines Regarding Defendants Joybuy, Joybuy Express, Joybuy Fashion, and Joybuy Selection (Defendants 135138) 41 filed by Jingdong E-commerce (Trade) Hong Kong Corporation Limited is granted. Defendants' responsive pleading due by 8/26/2022. Mailed notice

NOTICE of Voluntary Dismissal by Tangle Inc. of Defendants Nos. 108 and 115

MOTION by Plaintiff Tangle Inc. for default judgment as to Defaulting Defendants and Default Judgment

DECLARATION of Nathan Monroe-Yavneh regarding motion for default judgment 44

Exhibit A (Service Emails)

Exhibit B (Website)

Exhibit C (First Amended Schedule A)

(Exhibit D (Iron Maiden Order))

MEMORANDUM by Tangle Inc. in support of motion for default judgment 44

[Proposed] Default Judgment Order by Tangle Inc.

NOTICE of Voluntary Dismissal by Tangle Inc. of Defendant tkhan1220 (124)

STATUS Report by Tangle Inc.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic status and motion hearing held on 8/24/2022. For the reasons stated on the record, Plaintiff's motion for entry of default and default judgment 44 is granted. Enter order. All Joybuy defendants' unopposed oral motion to extend time to answer or otherwise plead to 9/19/2022 is granted. Telephonic status hearing set for 9/19/2022 at 9:30 a.m. Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

DEFAULT JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 8/24/2022. Mailed notice

SATISFACTION of Judgment regarding order 51 of Defendant Nos. 133 and 143

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing set for 9/19/2022 at 9:30 a.m. will now be held on the Webex platform. Members of the public and media may listen to these proceedings by dialing (650) 479-3207 the meeting number, access code, or PIN/ID is 1809883385. Counsel of record and other essential case participants will receive an email prior to the start of the video hearing with instructions to join the video conference. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Attorney Harry J. Moren to withdraw as attorney for Tangle Inc. No party information provided

Affidavit Affidavit in support of Motion for Withdrawal of Attorney of Record (Harry Moren)

(Text of Proposed Order Proposed Order)

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's motion for withdrawal of attorney Harry J. Moren as attorney of record for Plaintiff 54 is granted. Mailed notice

SATISFACTION of Judgment regarding order 51 of Defendant No. 18

ATTORNEY Appearance for Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) by Wallace Hua Feng (Jingdong Ecommerce (Trade) Hong Kong Corporation Limited)

MOTION by Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) for extension of time Unopposed Motion to Extend Deadlines Regarding Joybuy, Joybuy Express, Joybuy Fashion, and Joybuy Selection

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held via Webex held on 9/19/2022. Unopposed Motion To Extend Deadlines to 10/10/2022 to file its responsive pleadings Regarding Defendants Joybuy, Joybuy Express, Joybuy Fashion, And Joybuy Selection (Defendants 135138) 58 is granted. These parties remain in settlement negotiations. Telephonic hearing set for 10/20/2022 at 9:15 a.m. Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Plaintiff is directed to file a status report by 10/13/2022. Mailed notice

MOTION by Defendants Joybuy (135), Joybuy Express (136), Joybuy Fashion (137), Joybuy Selection (138) for extension of time Unopposed Motion to Extend Deadlines Regarding Joybuy, Joybuy Express, Joybuy Fashion, and Joybuy Selection

MINUTE entry before the Honorable Robert W. Gettleman: Unopposed motion to extend deadlines regarding defendants Joybuy, Joybuy Express, Joybuy Fashion, And Joybuy Selection (Defendants 135138) [60] is granted. Joybuy defendants' responsive pleadings due on or before 10/31/2022. No further extensions will be granted to these defendants. Mailed notice

STATUS Report by Tangle Inc.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing set for 10/20/2022 at 9:15 is stricken and reset to 10/20/2022 at 9:00 a.m. (TIME CHANGE ONLY). Members of the public and media may listen to these proceedings by dialing (888) 684-8852 and using the access code is 1503395. Counsel of record and other essential case participants will receive an email prior to the start of the telephone hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Robert W. Gettleman: Counsel has contacted the courtroom deputy and confirmed that the only remaining defendants Defendants Joybuy, Joybuy Express, Joybuy Fashion, and Joybuy Selection (Def. Nos. 135-138). These defendants' responsive pleadings are now due 10/31/2022. Accordingly, telephonic hearing set for 10/20/2022 is stricken and reset to 11/8/2022 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Members of the public and media may listen to these proceedings by dialing (650) 479-3207 the meeting number, access code, or PIN/ID is 1809883385. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

NOTICE of Voluntary Dismissal by Tangle Inc. of Defendants No. 135, 136, 137, and 138 (Joybuy Defendants).

MINUTE entry before the Honorable Robert W. Gettleman: Counsel has contacted the court that the last notice of voluntary dismissal [65] terminated the final parties in this case. Telephonic hearing set for 11/8/2022 is stricken. Civil case terminated. Mailed notice

MAILED Copyright report with certified copy of minute order dated 11/2/22 to Register of Copyrights, Washington, D.C.

(Certified Minute Order)

FULL SATISFACTION of Judgment regarding order 51 of Defendant No. 1 (Free Market Co., Ltd).