2022-cv-03139

COMPLAINT filed by BBC Studios Distribution Ltd; Filing fee $ 402, receipt number AILNDC-19564641.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Schedule A regarding complaint[1]

MOTION by Plaintiff BBC Studios Distribution Ltd for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BBC Studios Distribution Ltd

Notice of Claims Involving Trademarks by BBC Studios Distribution Ltd

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Isaku Begert

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Kahlia Roe Halpern

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.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiff BBC Studios Distribution Ltd for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for temporary restraining order 13

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 14

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Diane Hamer regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Exhibit 3 - Parts 1 - 5 regarding declaration 16

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

(Exhibit 3-5)

MOTION by Plaintiff BBC Studios Distribution Ltdfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for miscellaneous relief 18

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 19

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process 3 13 18 are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 7/1/2022. Notices mailed.

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

SURETY BOND in the amount of $ 50,000.00 posted by BBC Studios Distribution Ltd. (Document not scanned)

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order

MEMORANDUM by BBC Studios Distribution Ltd in support of extension of time 23

(Declaration of Isaku M. Begert)

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 23 is granted. The TRO is extended to 7/29/22.

MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction, MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order

Exhibit A

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for preliminary injunction, extension of time[27]

Declaration of Isaku M. Begert

Exhibit 1

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/26/2022, answer due 8/16/2022.

Declaration of Kahlia R. Halpern

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 7/29/22. If no objections are filed, the motion will be considered unopposed. Notices mailed.

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's motion for a preliminary injunction [27] is granted. No defendant has appeared or objected to the motion. The evidence submitted in support of the TRO also supports the entry of a preliminary injunction. Enter preliminary injunction. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 8/8/2022. Notices mailed.

NEW PARTIES: Changsha Dongguan Packaging Products Co., Ltd., Dongguan Sancai Paper Co., Ltd., Longyan Pinlan Trading Co., Ltd., Shishi Junxin Garment Accessories Co., Ltd., Shishi Junxin Yuanyi Trading Co., Ltd., Xianju Happy Year Gifts Factory, Yiwu Moyun Import And Export Co., Ltd., Yiwu Xinqi Packaging Co., Ltd., Yiwu Xintu Import And Export Co., Ltd., Yiwu Zimeng Trading Co., Ltd., Zhangjiagang Bai Xuan Import And Export Trade Co., Ltd., Zhangjiagang Jianier Clothing Co., Ltd., Diy Anime Home Toys Store, lovobabi Store, makus Store, Shop1100391230 Store, Shop911553397 Store, YiBenLun Birthday Party Store, A1YZUS2Q0OFDT0, A2NU7AEHPJRO2W, A2RO57Z0DN3S2V, A38DI7AODC0852, A3FB7DKSQINS8E, A3P1NO8BGRSFOH, Acute-shop, AIKUJHLOIGF, Amuse Park, AROAM, Baoteng, Breasha, BULUYI, Caiyangxym, chenbodebeimeidianpu, ChengGuBaiHuoDian US, CM Printing Co., Cparty, CTZONE, DACUIDEDIAN, Dalling, dandandedian, dayyh, dongguanshirilanhuazhuangpinyouxiangongsi1231, Eugenereston, Euttfon, FDHFGGRGD, Force Cleaning Services Company Limited, ganghan, GOLECHA, Gongqi e-com, GUANGZHOU FLY WALKING TRADING LIMITED, guopangpang, gymind, hefeipouwaishangmaoyouxiangongsi, henanlutuosishangmaoyouxiangongsi, huohuaqms8, JiNanDeKaShangMaoYouXianGongSi, JINGREN, jkhkjhkhjkgh, Jun-Lian, kangqidexiaodian, kangruida, kjkfhgkfjhgf, LAVENDA, liangzhangyun2, LieDunDianZiShangWuYouXianGongSi, little star shop, LiuQingPingDeGongSi, LIXIANCHAOSHI US, lklkjhjgfhg65, LUOXIAOHONG, ManHuanYou, mideasparty, MONIZEE, nieyanhe's shop, panxueee, Perfectionister-US, PEU, pomaostraws, qixinyue, seassol us, ShanShanLaiLa, shanxiliujiaxiangxuanmaoyiyouxiangongsi, shengheqiche666, shenzhen marine, Showmaker us, SIRONGBH, Sunuyun, suxiaojie, TO BUY, TRINITAS HK LiMiTEd, uidingguowenhuachuanmeiyoux, UKJKJSA, UOEMMRR, Viola-J, wandemaike, WEEPA, wuni, XIANGQIANKAN, xiaojingqidebeimeidianpu, XUSHANGBIANMIN US, YINGCHUNNIEDIAN, zhanghengde508, zheshizhuanmai, fengduo Buy, ROUXIN, Starynighty, TEN10CENT, Windy, Alexander Smith, linletao2154, liuguodong97515, xuji1177 and zanghuade4113 added to case caption.

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

MOTION by Attorney Isaku M. Begert to withdraw as attorney for BBC Studios Distribution Ltd. No party information provided

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Marcella Deshonda Slay

MOTION by Plaintiff BBC Studios Distribution Ltd to approve consent judgment as to a Certain Defendant

MOTION by Plaintiff BBC Studios Distribution Ltd for entry of default, MOTION by Plaintiff BBC Studios Distribution Ltd for default judgment as to all Defendants with the exception of Defendant Starynighty

(Exhibit A)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for entry of default, motion for default judgment, 39

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 40

(Exhibit 1)

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for default judgment must be properly filed by 9/9/22. If no objections are filed the motion will be considered unopposed. Notices mailed.

MINUTE entry before the Honorable Manish S. Shah: The motion to approve consent judgment as to defendant Starynighty 38 is granted. Enter consent judgment. The motion for entry of default judgment against the remaining defendants 39 is granted. No defendants have appeared to object to the motion. Based on the evidence submitted in support of the temporary restraining order and the admission of liability by virtue of the default, plaintiff has established that a permanent injunction should be entered. The infringement of plaintiff's intellectual property irreparably harms plaintiff and confuses the public. The infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by defendants, the strong value of the plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $100,000 is an appropriate award of statutory damages. Enter Default Judgment Order. Terminate civil case. Notices mailed.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 9/13/2022. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 9/13/2022. Notices mailed.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment regarding order 45 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 45 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 45 in the amount of $100,000 as to certain defendants

NOTICE of withdrawal of bond 26 by Greer, Burns & Crain, Ltd. (Attachment) (Received for Docketing on 11/7/2022)

FULL SATISFACTION of Judgment regarding order 45 in the amount of $100,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[45] in the amount of $100,000 as to certain defendant