2022-cv-05448

COMPLAINT filed by The Board of Trustees of the University of Alabama d/b/a the University of Alabama; Filing fee $ 402, receipt number AILNDC-19911753.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama Schedule A regarding complaint, [1]

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for leave to file under seal

CIVIL Cover Sheet

Notice of Claims Involving Trademarks by The Board of Trustees of the University of Alabama d/b/a the University of Alabama

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Jake Michael Christensen

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Rachel S Miller

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Allyson M. Martin

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for temporary restraining order Including a Temporary Injunction, Temporary Transfer of the Domain Names, Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by The Board of Trustees of the University of Alabama d/b/a the University of Alabama 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 Paul Mills regarding memorandum in support of motion 14

Exhibit 1

(Exhibit 2)

DECLARATION of Lindsay Conn regarding memorandum in support of motion 14

SEALED EXHIBIT by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama Exhibit 1 - Parts 1-5 regarding declaration 17

Exhibit 1-1

Exhibit 1-2

Exhibit 1-3

Exhibit 1-4

(Exhibit 1-5)

SEALED EXHIBIT by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama Exhibit 2 regarding declaration 17

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by The Board of Trustees of the University of Alabama d/b/a the University of Alabama in support of motion for miscellaneous relief 20

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 21

Exhibit 1

Exhibit 2

(Exhibit 3)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, domain transfer, asset restraint, and expedited discovery, and motion for electronic service of process [3] [13] [20] 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 10/25/2022. Notices mailed.

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

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

SURETY BOND in the amount of $ 50,000 posted by The Board of Trustees of the University of Alabama d/b/a the University of Alabama. (Document not imaged)

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for extension of time of Temporary Restraining Order

MEMORANDUM by The Board of Trustees of the University of Alabama d/b/a the University of Alabama in support of extension of time[26]

Declaration of Jake M. Christensen

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 26 is granted. The TRO is extended to 11/22/22. Notices mailed.

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for preliminary injunction

Exhibit A

MEMORANDUM by The Board of Trustees of the University of Alabama d/b/a the University of Alabama in support of motion for preliminary injunction[29]

Declaration of Jake M. Christensen

Exhibit 1

SUMMONS Returned Executed by The Board of Trustees of the University of Alabama d/b/a the University of Alabama as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/17/2022, answer due 12/8/2022.

Declaration of Rachel S. Miller

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 11/21/22. If no objections are filed, the motion will be considered unopposed. Notices mailed.

MINUTE entry before the Honorable Manish S. Shah: No defendants have appeared or objected to the motion for a preliminary injunction. The evidence in support of the TRO continues to support the entry of a preliminary injunction. The motion 29 is granted. 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 11/22/2022. Notices mailed.

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ATTORNEY Appearance for Defendant T&H Home by Timothy Tiewei Wang

MOTION by Defendant T&H Home for extension of time to file answer regarding complaint, [1]

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for entry of default, MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama for default judgment as to all Defendants with the exception of a certain Defendant

Exhibit A

MEMORANDUM by The Board of Trustees of the University of Alabama d/b/a the University of Alabama in support of motion for entry of default, motion for default judgment, [37]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[38]

Exhibit 1

NOTICE of Motion by Jake Michael Christensen for presentment of motion for entry of default, motion for default judgment, [37] before Honorable Manish S. Shah on 12/14/2022 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer [36] is granted. Defendant T&H Home has until 1/7/23 to respond to the complaint. Notices mailed.

ATTORNEY Appearance for Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama by Kahlia Roe Halpern

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment 37 is granted. Enter Default Judgment. Terminate civil case. Notices mailed.

FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/14/2022. Notices mailed.

ANSWER to Complaint with Jury Demand by T&H Home

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by T&H Home

STATUS Report Joint by The Board of Trustees of the University of Alabama d/b/a the University of Alabama

MINUTE entry before the Honorable Manish S. Shah: The remaining parties shall exchange initial disclosures by 3/3/23 and all fact discovery must be noticed in time for completion by 11/6/23. The court will set a dispositive motion deadline when the parties get closer to completing fact discovery. The parties shall file a discovery and settlement progress report on 4/27/23. Notices mailed.

MOTION by Plaintiff The Board of Trustees of the University of Alabama d/b/a the University of Alabama to approve consent judgment as to Defendant T&H Home (Joint)

NOTICE of Motion by Jake Michael Christensen for presentment of motion to approve consent judgment[49] before Honorable Manish S. Shah on 3/14/2023 at 09:45 AM.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 3/8/2023: The motion to approve consent judgment 49 is granted. No appearance on 3/14/23 is necessary. Notices mailed.

FULL SATISFACTION of Judgment regarding order 44 in the amount of $100,000 as to certain defendants

FULL SATISFACTION of Judgment regarding order 44 in the amount of $100,000 as to certain defendant