2022-cv-04642

COMPLAINT filed by Bad Vibes Forever, LLC; Filing fee $ 402, receipt number AILNDC-19794393.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED DOCUMENT by Plaintiff Bad Vibes Forever, LLC Schedule A to Complaint [1]

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Bad Vibes Forever, LLC

ATTORNEY Appearance for Plaintiff Bad Vibes Forever, LLC by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Bad Vibes Forever, LLC by Adam Grodman

ATTORNEY Appearance for Plaintiff Bad Vibes Forever, LLC by Yi Bu

ATTORNEY Appearance for Plaintiff Bad Vibes Forever, LLC by Yanling Jiang

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.

Schedule A [2] to Complaint [1] by Bad Vibes Forever, LLC

MEMORANDUM In Support of [10] Ex Parte Motion

Declaration of Keith A. Vogt

Exhibit 1-2, Declaration of Keith Vogt

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable John J. Tharp, Jr: On the grounds set forth in the motion, the plaintiff's ex parte motion for leave to conduct expedited discovery and electronic service of process 10 is granted in part. Discovery is limited to information necessary to identify and serve the defendants. Enter order. Mailed notice

ORDER For Leave To Conduct Expedited Discovery And Electronic Service of Process Signed by the Honorable John J. Tharp, Jr on 9/12/2022. Mailed notice

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

SUMMONS Returned Executed by Bad Vibes Forever, LLC as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/22/2022, answer due 10/13/2022.

(Declaration of Service)

MOTION by Plaintiff Bad Vibes Forever, LLC to approve consent judgment and Permanent Injunction as to [Certain] Defendants

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of consent final judgment and permanent injunction [17] is granted. Enter consent judgment. Mailed notice

STIPULATED Consent Judgment Signed by the Honorable John J. Tharp, Jr on 10/21/2022. Mailed notice

MOTION by Plaintiff Bad Vibes Forever, LLC for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Bad Vibes Forever, LLC in support of motion for default judgment[20]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Declaration of Robert A. Celestin, Esq.

MINUTE entry before the Honorable John J. Tharp, Jr:Plaintiff's motion for entry of default and default judgment 20 is taken under advisement. Any objections or responses are due by 11/03/2022. Mailed notice

MINUTE entry before the Honorable John J. Tharp, Jr:The plaintiff's motion for entry of default and default judgment 20 is denied without prejudice. The plaintiff's complaint alleges in conclusory form and on information and belief that the defendants as a class have acted in accordance with global trends in online counterfeiting. The plaintiff takes no steps, however, in its complaint or otherwise, to detail why each of the 250 defendants it seeks judgment against are individually liable for trademark infringement. The granting of default judgment is within the Court's discretion. Fed. R. Civ. P. 55(b)(2). Without factual allegations showing how each individual defendant has plausibly infringed (a showing that is presumably within the plaintiff's capacity, e.g., by filing screen images of the defendants' online infringing activity, as is the practice with the vast majority of similar cases), default judgment is not warranted. Mailed notice

MOTION by Plaintiff Bad Vibes Forever, LLC for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Bad Vibes Forever, LLC in support of motion for default judgment 24

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

(Declaration of Robert A. Celestin, Esq.)

EXHIBIT by Plaintiff Bad Vibes Forever, LLC Exhibit 1, Declaration of Robert A. Celestin, Esq. in Support of 25 regarding memorandum in support of motion 25

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Exhibit 1-4

Exhibit 1-5

Exhibit 1-6

Exhibit 1-7

Exhibit 1-8

Exhibit 1-9

Exhibit 1-10

(Exhibit 1-11)

MINUTE entry before the Honorable John J. Tharp, Jr:No defendant having objected, the plaintiff's motion for default judgment 24 is granted. Enter default judgment order. Civil case terminated. Mailed notice

DEFAULT Judgment Order Signed by the Honorable John J. Tharp, Jr on 11/15/2022. Mailed notice

SATISFACTION of Judgment as to [Certain] defendants

MINUTE entry before the Honorable John J. Tharp, Jr: Upon plaintiff's report of full satisfaction of judgment 29, the Court, pursuant to LR 58.1, enters the satisfaction of judgment as to defendants Nos. 156, 157, 186, 200, 224, and 236. Mailed notice