2022-cv-04936

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 402, receipt number AILNDC-19832956.

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.

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. (jk2,)

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]

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

MINUTE entry before the Honorable Manish S. Shah: Plaintiffs' ex parte motion for a temporary restraining order, asset restraint, expedited discovery, and electronic service of process, motion for excess pages, and motion to seal [9][10][11] are granted. The plaintiffs' written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiffs' interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits as to the defendants listed in the Schedule A, the harm to plaintiffs is irreparable, and an injunction is in the public interest because infringement interferes with the plaintiffs' ability to control their intellectual property and causes consumer confusion. 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. Given the number of defendants and the risk of improper joinder resulting in an improper injunction, the court requires a $100,000 bond to secure the injunction, and it must be posted within one week. Enter Sealed TRO. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/11/2022. Notices mailed.

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

SURETY BOND in the amount of $ 100,000 posted by Ground Works Co., Ltd., Khara Inc.

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 10/20/2022, answer due 11/10/2022.

Declaration of Service

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 10/25/22. If no objections are filed, the motion will be considered unopposed. Notices mailed.

ATTORNEY Appearance for Defendant jill_punkxloli by Brian Swift

MOTION by Defendant jill_punkxloli for extension of time to file answer

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

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment 25

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

ATTORNEY Appearance for Defendant kunmingfangquedianzishangwuyouxiangongsi by Yong Chen

MOTION by Defendant kunmingfangquedianzishangwuyouxiangongsi for extension of time to file answer regarding complaint 1 UNOPPOSED

MINUTE entry before the Honorable Manish S. Shah: The motions for extension of time 24 28 are granted. Defendant jill_punkxloli and defendant kunmingfangquedianzishangwuyouxiangongsi have until 12/1/22 to respond to the complaint. Any objections to the motion for default judgment (as to other defendants who have not appeared) 25 must be properly filed by 11/21/22. If no objections are filed, the motion will be considered unopposed. No objections having been filed to the motion for preliminary injunction, the motion 19 is granted and the court converts the TRO to a Preliminary Injunction that will remain in effect during the pendency of this case.

NOTICE of Voluntary Dismissal by All Plaintiffs As to [Certain] defendants

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant no. 155 kunmingfangquedianzishangwuyouxiangongsi

MINUTE entry before the Honorable Manish S. Shah: No defendants subject to the motion for default judgment have entered appearances or objected to the motion. The motion 25 is granted. Based on the admission of liability by virtue of the default, plaintiffs have established that defendants willfully infringe plaintiff's copyright. Equitable relief is appropriate, because plaintiffs are irreparably harmed by the loss of exclusivity and a permanent injunction is appropriate to redress that harm. No harm to defendants exists from an injunction ordering them not to infringe plaintiffs' intellectual property. Statutory damages in the amount of $100,000 per defendant is appropriate to deter infringement that is easy to commit, and after considering the absence of any evidence about lost profits or actual harm. Enter default judgment order. Plaintiffs shall file a status report as to the remaining defendants by 12/7/22. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 11/30/2022. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 128 fangxiaolaxiaochishop

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 7 jill_punkxloli

STATUS Report by Ground Works Co., Ltd., Khara Inc.

MINUTE entry before the Honorable Manish S. Shah: All claims against all parties have been resolved. Terminate civil case. Notices mailed.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

(Closing Minute Entry dated 12/8/2022)

SATISFACTION of Judgment as to defendant no. [guanbin] GENOBL

SATISFACTION of Judgment as to defendant no. 201 SYNING

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 140 High End Boutique Collection

SATISFACTION of Judgment as to defendant no. 68 means zore

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 7 jill_punkxloli