2022-cv-04199

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 402, receipt number AILNDC-19728914.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yi Bu

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Adam Grodman

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ground Works Co., Ltd., Khara Inc.

CASE ASSIGNED to the Honorable Thomas M. Durkin. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file under seal

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file excess pages

MEMORANDUM in support of 11 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Yasuhiro Kamimura

(Exhibit 1, of Yasuhiro Kamimura's declaration)

SEALED EXHIBIT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Sealed Exhibit 2, Declaration of Yasuhiro Kamimura regarding memorandum in support of motion, 12

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

(Exhibit 2-4)

Schedule A [2] to Complaint [1] by Plaintiff (Public-Redacted) by Ground Works Co., Ltd., Khara Inc.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

MINUTE entry before the Honorable Thomas M. Durkin: Plaintiffs' motion for leave to file under seal 9 and motion to exceed page limitation 10 are granted. Plaintiffs' ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 11 is granted. Enter order. Mailed notice.

SEALED Temporary Restraining Order. Signed by the Honorable Thomas M. Durkin on 8/11/2022. Mailed notice.

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

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for preliminary injunction

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for preliminary injunction[19]

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith Vogt

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/17/2022, answer due 9/7/2022.

Declaration of Service

MINUTE entry before the Honorable Thomas M. Durkin: Telephonic hearing as to motion for preliminary injunction 19 set for 8/24/2022 at 08:45 AM. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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.

SURETY BOND in the amount of $ 10,000.00 posted by Khara Inc. (Document not scanned)

MINUTE entry before the Honorable Thomas M. Durkin: Telephonic motion hearing held on 8/24/2022. No one appeared on behalf of any defendants. Plaintiff's motion for entry of a preliminary injunction [19] is granted. Enter Preliminary Injunction Order. The Clerk's office is directed to unseal Plaintiffs' Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Yasuhiro Kamimura [13], and the TRO [18]. Plaintiff's counsel is ordered to add ALL Defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website www.ilnd.uscourts.com/instructions. A telephonic status hearing is set for 9/23/2022 at 9:00 a.m., unless a hearing on a motion for default is scheduled before then. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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.

PRELIMINARY Injunction Order. Signed by the Honorable Thomas M. Durkin on 8/24/2022. Mailed notice.

NEW PARTIES: liyang82383, liyuting1, lizhch, lizhenglun2553, lizhenzhen8s8s3, liziyi3202, ljifehaya, llq88889999, lodivhjtg, Lofun Zaitou Komping, loovjfg, Louie H Perez, love yu, Lovely style company, Luis Borel, lujiazhen92883, Lujings womanclothes, Lum Phi Ni_Wear, luoqi4455, luornpeng, luoruixiang2580, luossphone, luoxiaoliang fashion, luoyanhui12345, luqianlai fashion, lushengwen6310, LZX8910, mabo fashion, mage666, magicshop2014, Mahorse snowy, Mai Yang, majingrui62, mali fashion, MALING998, MaMa Maker International, MAMAD, mameilizhu, mammiyami, Man has invented machines larger than man's power, maofeng Store me, Margaret Needham, mariajosevesn, Mariesha Williams, mark Persaud, markgeffers4, matteoantho, Matthew J May, mayihua68310 and medhurstdomingo added to case caption.

NEW PARTIES: sanseng, sanshu, sara swan, Sarengaowa, schmafrnckwiet, Scott Johnson1, scr3f, sd7hg89sdkgh, sdtfgGSGFD, Selleveryday, sfderg shopping, Sgchvhcjvhbgnhbjvbvv, shangzhenfei3826, shanshan2015, shaoqiu fashion, Shaw Investing Gold, Shcgvfhcjchchvnvgvvvbcbvc, shelbyyya, shenjiejiulin, shenjun95339, shenqijun5866, ShipaijiezongnIh, shiqu1carstyle, Shirley R Constable, ShirleyfHnHk, shiyani0016, shopkeepers, shuyanxu, siling wholesale store, simple_yu, SIQIULIU, Skfneodnwofnsifnsinfsi64, Sknxxmmmxdnnxjxknxmxnm, SOLASI, Songchenhui820, songruibin5847, Songxil, Sophias shopping center, Spring Vandiver, springd, stevebechtelar78, Steven Heimerl Z, Study well and make progress every day, sujiedongstore, sunfengchun, sunguiru, sunxiaoqu an6688, sunyang fashion, superstarsupplier, svrcbhf, SYBELAR, tainrenxin85696, tandanhua76494 and TANFANG9528 added to case caption.

MINUTE entry before the Honorable Thomas M. Durkin: The telephonic status hearing set for 9/23/2022 at 9:00 a.m. is reset for 9:45 a.m. Time change only. Mailed notice.

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for default judgment as to The Defendants Identified In Schedule A

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment 27

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 27 before Honorable Thomas M. Durkin on 9/23/2022 at 09:45 AM.

MINUTE entry before the Honorable Thomas M. Durkin: Hearing for presentment of the motion for default judgment 27 set for 9/23/2022 at 9:45 a.m. will proceed by telephone. To join the telephone conference, dial 877-402-9757, Access Code 4410831. Members of the public and media will be able to call in to listen to this hearing. Please be sure to keep your phone on mute when you are not speaking. 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 Ground Works Co., Ltd., Khara Inc.

MINUTE entry before the Honorable Thomas M. Durkin: Motion hearing held on 9/23/22. Plaintiff's motion for default and default judgment against the Defendants identified in the amended schedule A 27 is granted in the amount of $150,000 per Defendant. Enter final judgment order. Civil case terminated.

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Thomas M. Durkin on 9/23/22.

AMENDED DEFAULT FINAL JUDGMENT ORDER signed by the Honorable Thomas M. Durkin on 9/29/2022. Mailed notice.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Khara Inc. and Ground Works Co., Ltd. to Keith A. Vogt, Keith Vogt, Ltd. 33 West Jackson Boulevard Unit #2W Chicago, IL 60604 via certified mail #7001 2510 0002 3701 4188.