2022-cv-04440

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 402, receipt number AILNDC-19763492.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

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 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 Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Jeffrey Cummings. 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]

MEMORANDUM Establishing that Joinder is Proper

Declaration of Keith A. Vogt

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

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

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's motion for leave to file under seal [9], motion for leave to file excess pages [10], and ex parte motion for a temporary restraining order [11]. Provided that Plaintiff provides the security described in paragraph 11 of the temporary restraining order, the temporary restraining order shall become effective on December 20, 2022 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Franklin U. Valderrama on 12/13/2022. Mailed notice

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

SURETY BOND in the amount of $ $10,000 posted by Khara Inc. (Document not scanned)

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for extension of time for Temporary Restraining Order

MINUTE entry before the Honorable Franklin U. Valderrama: The Court hereby grants Plaintiff's Motion to Extend the Temporary Restraining Order [20]. The Temporary Restraining Order [18] shall now expire on 1/17/2023 at 6:00 p.m. Emailed notice

ORDER ON MOTION FOR EXTENSION OF TEMPORARY RESTRAINING ORDER: Signed by the Honorable Franklin U. Valderrama on 12/29/2022. Emailed notice

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice.

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 24

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's declaration)

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/30/2022, answer due 1/20/2023.

(Declaration of Service)

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 144 Thomasdai Toy Store

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 167 ZHONGU Store

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for default judgment as to for Entry of Default and Default Judgment Against the Defendants Identified in First Amended Schedule A

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment 29

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, Plaintiff's motion for entry of default and default judgment 29 is granted. Enter Final Judgment Order. The Ten Thousand Dollars ($10,000) surety bond posted by GWC is hereby released to GWC or its counsel, Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois 60604. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to GWC or its counsel. The motion for preliminary injunction 24 is terminated as moot. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER. Signed by the Honorable Franklin U. Valderrama on 4/7/2023. Mailed notice.

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W, Chicago, Illinois 60604 via certified mail # 7019 2280 0000 0963 1873.

SATISFACTION of Judgment as to defendant no. 45 FunnyGame Store