2022-cv-06079

COMPLAINT filed by John Doe; Jury Demand. Filing fee $ 402, receipt number AILNDC-20009950.

Exhibit 2

(Exhibit 3)

SEALED DOCUMENT by Plaintiff John Doe Exhibit 1 to Complaint

SEALED DOCUMENT by Plaintiff John Doe Schedule A to Complaint

SEALED DOCUMENT by Plaintiff John Doe Amended Complaint

Exhibit 1

Exhibit 2

Exhibit 3

(Supplement Schedule A)

CIVIL Cover Sheet

SEALED DOCUMENT by Plaintiff John Doe Ex Parte Motion for Entry of Temporary Restraining Order and Expedited Discovery

SEALED DOCUMENT by Plaintiff John Doe Memorandum in Support of Ex Parte Motion for Entry of Temporary Restraining Order and Expedited Discovery

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Text entry; no document attached.)

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. (Text entry; no document attached.)

SEALED DOCUMENT by Plaintiff John Doe Declaration in Support of Ex Parte Motion for Entry of Temporary Restraining Order and Expedited Discovery

Exhibit 1

Exhibit 2

(Exhibit 3)

MOTION by Plaintiff John Doe for service by publication Motion for Leave to Serve Process Electronically

Memorandum in Support of Motion for Electronic Service of Process by John Doe

MOTION by Plaintiff John Doe to seal document sealed document 7, sealed document 4, sealed document 8, sealed document 3, sealed document 2, sealed document 6

Motion to Proceed Anonymously by John Doe

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion to seal document 11, motion for service by publication 9 before Honorable John Robert Blakey on 11/17/2022 at 11:00 AM.

ATTORNEY Appearance for Plaintiff John Doe by Theodore Joseph Chiacchio

ATTORNEY Appearance for Plaintiff John Doe by Shengmao Mu

MAILED copyright request letter to counsel of record Shengmao Mu.

SEALED MOTION by Plaintiff John Doe

Declaration Moebius Declaration

Exhibit 1

Exhibit 2

(Exhibit 3)

MEMORANDUM by John Doe in support of Sealed motion[17]

SEALED DOCUMENT by Plaintiff John Doe

MOTION by Plaintiff John Doe to seal document sealed document[19]

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion to seal document[20] before Honorable John Robert Blakey on 11/22/2022 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Oral motion to appear via telephone for the 11/17/2022 hearing is granted. Counsel/Parties shall call 877-402-9753 and utilize participant code 9955840. 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

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants Plaintiff's motions for leave to file under seal 11, 20 and motion for electronic service of process 9. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order 17. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 11/30/22. The 11/17/22 and 11/22/22 Notice of Motion dates are stricken. Mailed notice

SEALED ORDER Signed by the Honorable John Robert Blakey on 11/17/2022. Mailed notice

MOTION by Plaintiff John Doe for extension of time Motion to Extend Sealed Temporary Restraining Order [24]

MOTION by Plaintiff John DoeMotion for Leave to Appear Telephonically

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for miscellaneous relief[26], extension of time[25] before Honorable John Robert Blakey on 11/22/2022 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court takes Plaintiff's motion to extend [25] under advisement, strikes the 11/22/22 Notice of Motion date, and denies as moot Plaintiff's motion to appear telephonically [26]. As noticed, the motions fail to comply with the Court's standing order. In the future, the Court will strike any non-complying motions. Mailed notice

BOND in the amount of $ 10000.00 posted by John Doe Receipt number 4624279405 (Text entry; no document attached.)

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motion to extend [25] the temporary restraining order entered 11/17/22 [24]. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 12/14/22. Mailed notice

SUMMONS Issued as to Defendant individuals (Text entry; no document attached.)

MOTION by Plaintiff John Doe for preliminary injunction

Memorandum In Support of Motion for Entry of Preliminary Injunction by John Doe

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for preliminary injunction 30 before Honorable John Robert Blakey on 12/15/2022 at 11:00 AM.

MINUTE entry before the Honorable Steven C. Seeger: Judge Seeger will preside over a hearing on Plaintiff's motion for a preliminary injunction on December 15, 2022 at 11:00 a.m. in his capacity as the Emergency Judge. The hearing will be held by telephone conference. Members of the public and media will be able to call in to listen to this hearing. The call-in number is (888) 684-8852 and the access code is 9369830. 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. Plaintiff's counsel must provide notice of the hearing to Defendants and file a certificate of service. Mailed notice.

CERTIFICATE of Service by Theodore Joseph Chiacchio on behalf of John Doe regarding set/reset hearings, [33]

ATTORNEY Appearance for Defendant individuals by Cory Jay Rosenbaum for Defendant Panther Print

MOTION by Defendant individualsto prevent injunction as to Defendant Panther Print

(Declaration)

ATTORNEY Appearance for Defendant Panther Print by Cory Jay Rosenbaum (Docket Text Modified on 12/16/2022).

DECLARATION of Defendant Panther Print in support of motion to prevent permanent injunction

STATUS Report by John Doe

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for a preliminary injunction (Dckt. No. 30) is hereby granted in part and denied in part. Based on the record, the Court (meaning Judge Seeger, sitting in the capacity as the emergency judge) largely grants the motion because it is consistent with the facts and with the prior rulings of Judge Blakey. That said, the preliminary injunction largely does not apply to Defendant Panther Print, who appeared and opposed the motion. The Court makes that point in the last paragraph of the accompanying Preliminary Injunction Order. Based on the record (including the small number of sales, and the collateral damage that an injunction could cause for the sale of non-infringing products), the Court has determined that more limited injunctive relief is appropriate. Based on the record, Panther Print's Etsy store and frozen funds shall be immediately released. Panther Print shall refrain from selling any of the alleged infringing items set forth in the Complaint, specifically the Audrey Hepburn bubblegum chewing gum and Marilyn Monroe pink bubble gum canvas wall art picture prints. Defendant Panther Print's motion to prevent injunction (Dckt. No. 36) is thus granted in part and denied in part. The parties may seek additional relief from Judge Blakey as they deem appropriate. Mailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 12/18/2022. Mailed notice.

NOTICE of Voluntary Dismissal by John Doe Dismissal of Doe No. 363

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 42, this case is dismissed with prejudice as to Defendant memgmengzezestoreidentified. Mailed 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 Plaintiff John Doe for default judgment as to the Defendants identified on Redacted Schedule A

Memorandum In Support of Motion for Entry of Default and Default Judgment by John Doe

(Supplement Redacted Schedule A)

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for default judgment 45 before Honorable John Robert Blakey on 1/18/2023 at 11:00 AM.

Corrected [46-1], Redacted Schedule A by John Doe

MINUTE entry before the Honorable John Robert Blakey: The Court directs the Clerk to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add Plaintiff's full name and add all defendants listed on Schedule A to the Court's docket within three business days. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Also, to the extent summons has been returned executed, Plaintiff shall file the return on the docket. Mailed notice

NEW PARTIES: Michael Moebius added to case caption. Terminating John Doe (Text entry; no document attached.)

SUMMONS Returned Executed by Michael Moebius as to The Individuals Corporations, Limited Liabilities Companies, Partnerships, and Unicorporated Assoications on 12/9/2022, answer due 12/30/2022. (Docket Text Modified by Clerk's Office) Modified on 1/12/2023.

NEW PARTIES: DOE 1 guangzhouqipingmaoyi, DOE 2 Laoife Direct, DOE 3 LuckyBamboo, DOE 4 Madepants, DOE 5 TikTok Studio, DOE 6 wenwenshangmaopu, DOE 7 [ oLo Art Gallery] Wholesale Retail Oil Paintings, DOE 8 172 LT cases Store, DOE 9 1998 Art Store, DOE 10 235 TipTop Store, DOE 11 238 floor mat Store, DOE 12 3Cases Accessories Factory Store, DOE 13 7+1 Life Store, DOE 14 782668510art Store, DOE 15 A small mobile phone case shop that loves comics and animation Store, DOE 16 Ace Air Art Hobby Decoration Store, DOE 17 Actor Art Store, DOE 18 Adornment Life Store, DOE 19 AICHIYAGAO Store, DOE 20 Alice Custom For You, DOE 21 AliPaint Store, DOE 22 AliPoster Store, DOE 23 Amy Decal Store, DOE 24 Anime Nation Store, DOE 25 Anime Phone Accessories Store, DOE 26 AnKeLa Store, DOE 27 Anna Cooer Store, DOE 28 Anna Xuan Store, DOE 29 Art Furniture Fainting Store, DOE 30 Art Magic Shop Store, DOE 31 Art residence Store, DOE 32 Artcraft Painting Store, DOE 33 Artistic Creation Store, DOE 34 ArtPoster Store, DOE 35 Atoz Cushion Store, DOE 36 Atoz Mask Store, DOE 37 Autumn Wall Art Store, DOE 38 Baby Wendy Store, DOE 39 Bag Art Store, DOE 40 bai du Store, DOE 41 Baileys Art Store, DOE 42 BanDai Phone case Store, DOE 43 Bansky Store, DOE 44 Best Print Store, DOE 45 Bigwig Store, DOE 46 BlingArt Store, DOE 47 Bo Bo Art, DOE 48 Boku Dropship Store, DOE 49 BoomCase Store, DOE 50 BrotherDream Beautify Store, DOE 51 Buy art Store, DOE 52 Caliburn Store, DOE 53 Canvas Painting Flagship Store Store, DOE 54 CasesUFO Store, DOE 55 CHAMPRINT Throw Blankets Store, DOE 56 Chanpoetry Official Store, DOE 57 CHENLAIART Official Store, DOE 58 CHENYI Official Store, DOE 59 CLSTROSE Official Store, DOE 60 Colorful Cloud ART Store, DOE 61 conquer the world Store, DOE 62 Cotton T shirt 327 Store, DOE 63 Cozy Wall&Art Store, DOE 64 cute pet cute pet diamand painting Official Store, DOE 65 D-Dissney Store, DOE 66 Dabi Dropship Store, DOE 67 Deco Art Store, DOE 68 demlfen teetop Store, DOE 69 DIAMANT PAINTING Official Store, DOE 70 Disney-Poster Store, DOE 71 DIYNO.17 Store, DOE 72 DK-ART Store, DOE 73 DPP16 Store, DOE 74 DropshippingNine Store, DOE 75 Dropshippings Store, DOE 76 Dropshippingselven Store, DOE 77 DropshippingTen Store, DOE 78 E-House Store, DOE 79 erdongR Store, DOE 80 Eric and May GIRAFFEHOMELOVER Store, DOE 81 Eric and May XiaoNianGao Lover Store, DOE 82 E On Walls Art Store, DOE 83 Fa Dropship Store, DOE 84 Fanno Bag Store, DOE 85 FOOCAME Official Store, DOE 86 FR Art Store, DOE 87 funny days Store, DOE 88 Funny Phone Accessories Store, DOE 89 FunnyPrintShirt Store, DOE 90 futuer Store, DOE 91 GATYZTORY Painting Store, DOE 92 GATYZTORY Store, DOE 93 ggcc137 Store, DOE 94 Gibby Store, DOE 95 Gift Phone Accessories Store, DOE 96 gongzhi wall art Store, DOE 97 Good Canvas Painting Store Store, DOE 98 Goodlife Diamond Painting Store, DOE 99 Gryan Official Store and DOE 100 GY Home Decor Store added to case caption. (Text entry; no document attached.)

SUMMONS Returned Executed by Michael Moebius

NEW PARTIES: Doe 101 HAOCHU Home Painting Store, Doe 102 Hello Gallery Store, Doe 103 Hi Fun Supplies Store, Doe 104 Home Depot Store, Doe 105 HoneyTalk 902 Store, Doe 106 HoozGee Global Store, Doe 107 Hots Phone Accessories Store, Doe 108 HOTSALECASE90 Store, Doe 109 Hrmes Store, Doe 110 HT Painting Art Store, Doe 111 HZ Canvas Store, Doe 112 HZ Dream Store, Doe 113 IKU Art Store, Doe 114 Itami Store, Doe 115 Jasber Wall Art Store, Doe 116 Jieegee Imxinxx Official Store, Doe 117 Jvogue Wall&Art Store, Doe 118 JYCY Store, Doe 119 JYJC Clothes Store, Doe 120 JYJC Women Store, Doe 121 KDH.7 Store, Doe 122 KK77 Art Store, Doe 123 KK88 Art Store, Doe 124 KK99 Art Store, Doe 125 Krajews Factory Cases Store, Doe 126 L3187 Store, Doe 127 li an Store, Doe 128 LIDUS Bedding Store, Doe 129 Little PP Art Store, Doe 130 Living Wall Art Shop Store, Doe 131 Liwell Factory Store, Doe 132 LO&VE Wall Decor Store, Doe 133 Love Anime Decoration Store, Doe 134 LPW Decor Store, Doe 135 Luckyly Art Store, Doe 136 Manga Cushion Store, Doe 137 ManSheng Art Store, Doe 138 ManYun Art Store, Doe 139 Margot Drop Shipping Store, Doe 140 mfour Store, Doe 141 MINI Store, Doe 142 MobilePhoneCase Store, Doe 143 Modern-Art Store, Doe 144 mone Store, Doe 145 Monkey Wall Signs Store, Doe 146 moon cat Store, Doe 147 MoonArt Store, Doe 148 MSSugar Art Store, Doe 149 MUMUCASE MUMUCASE2 Store and Doe 150 mvensh Official Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 151 Na Na Art Store, Doe 152 NA168 Store, Doe 153 Nabi Official Store, Doe 154 Near Luck 777 Store, Doe 155 New Life Decor Store, Doe 156 New World Artwork Store, Doe 157 NHDARC Official Store, Doe 158 NICOLESHENTING Official Store, Doe 159 NNBF Store, Doe 160 No-2 Art Store, Doe 161 NovaArt Store, Doe 162 Ohh Yee Store, Doe 163 otoi Store, Doe 164 Painting decoration company Store, Doe 165 Painting Room Decor Store, Doe 166 PettyPhoneCase Store, Doe 167 PhoneCase Maker Store, Doe 168 Piao Xue Store, Doe 169 Pop Art Store, Doe 170 Populars Phone Accessories Store, Doe 171 Purple stone Store, Doe 172 Relax Life Fashion Wall Decor Store, Doe 173 Reminisce Cases Store, Doe 174 Resolution Store, Doe 175 ROWNOCEAN Store, Doe 176 RUOPOTY Diamonds Painting Store, Doe 177 S-ART Store, Doe 178 SellingCases Store, Doe 179 ShenZhen SYF International Co., Ltd, Doe 180 Shop New 97 Store, Doe 181 Shop11000088 Store, Doe 182 Shop1100035186 Store, Doe 183 Shop1100218670 Store, Doe 184 Shop1100287411 Store, Doe 185 Shop1100352527 Store, Doe 186 Shop1100368480 Store, Doe 187 Shop1102057482 Store, Doe 188 Shop1102080463 Store, Doe 189 Shop1102121871 Store, Doe 190 Shop1102132088 Store, Doe 191 Shop1102144119 Store, Doe 192 Shop1102160421 Store, Doe 193 Shop1102276189 Store, Doe 194 Shop1268595 Store, Doe 195 Shop1795578 Store, Doe 196 Shop218850 Store, Doe 197 Shop2782075 Store, Doe 198 Shop4546025 Store, Doe 199 Shop4709049 Store and Doe 200 Shop5365126 Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 201 Shop5406053 Store, Doe 202 Shop5517070 Store, Doe 203 Shop5623191 Store, Doe 204 Shop5721121 Store, Doe 205 Shop5876336 Store, Doe 206 Shop5890678 Store, Doe 207 Shop910349112 Store, Doe 208 Shop910352032 Store, Doe 209 Shop910895031 Store, Doe 210 Shop910943042 Store, Doe 211 Shop911022051 Store, Doe 212 Shop911253198 Store, Doe 213 Shop911256354 Store, Doe 214 Shop911427076 Store, Doe 215 Shop911538127 Store, Doe 216 Shop911557063 Store, Doe 217 Shop911599394 Store, Doe 218 Shop912625391 Store, Doe 219 Si Di Ke Decor Painting Store, Doe 220 Since97 Art Store, Doe 221 SkateDeco Specialist Store, Doe 222 Sky Art International Trade Co., Ltd., Doe 223 Smil 21650065 Store, Doe 224 Starry Sky Art Store, Doe 225 stras in the deeping dahai Store, Doe 226 Stylish Phone Accessories Store, Doe 227 Sunshine Art Store, Doe 228 Superxx Store, Doe 229 Sweetness Wall Art Store, Doe 230 SWM-Home Store, Doe 231 T-SHIRT 8 Store, Doe 232 TGIF Art Store, Doe 233 Tiffanie Store, Doe 234 TikToks Phone Accessories Store, Doe 235 TinAngel Store, Doe 236 TLCHART Store, Doe 237 To decor art Store, Doe 238 Tomorrow Art Poster Store, Doe 239 TOPLB102 Store Store, Doe 240 TOPLB103 Store, Doe 241 Touoilp Official Store, Doe 242 UJIOM Store, Doe 243 Unique Phone Accessories Store, Doe 244 Universal Art Store, Doe 245 UPUPUP ART Store, Doe 246 Vikineey Tshirt Store, Doe 247 Wan Go 780 Store, Doe 248 wanghong6 Store, Doe 249 WantOneCase Store and Doe 250 Warm Art Decor Store added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 251 Warm living art Store, Doe 252 Warm stars art Store, Doe 253 Warmness Art Prints Store, Doe 254 Well Pillow Store, Doe 255 Winifred Official Store, Doe 256 Winsom Store, Doe 257 WULA PHONE CASE Store, Doe 258 WY Art Store, Doe 259 Xaviera Official Store, Doe 260 XIAO SHUO DIAN Store, Doe 261 XiaoHeiQWQ Store, Doe 262 XiaoHuangQAQ Store, Doe 263 Xu Shi Yin Store, Doe 264 YaoBo factory Store, Doe 265 YIRAN Art Store, Doe 266 YNDFCNB119 Store, Doe 267 YOYOYU ART HOME DECOR JACKIE Store, Doe 268 YUN ART DECOR Store, Doe 269 YUTTEE Diamond Painting Store, Doe 270 YX-CC99 Warm Store, Doe 271 YY 113 Store, Doe 272 YY77 Art Store, Doe 273 yyytshirt Store, Doe 274 Z-B Dazzling Art Store, Doe 275 ZEGUUER Store, Doe 276 ZHIMZHE Official Store, Doe 277 ZLEY Phone Accessories Store, Doe 278 Zoo Art Store, Doe 279 Zorro-Yogurt Home Store, Doe 280 ZUIDIDE Store, Doe 281 ZYGALLOP Official Store, Doe 282 ZYJC Store, Doe 283 ZYJY Store, Doe 284 ZZ House Store, Doe 285 Spectrum Art and Design, Doe 286 CanvasArtsprints, Doe 287 Designo Prints, Doe 288 glitterandgumption, Doe 289 reka_products, Doe 290 rmboutique, Doe 291 tdm422, Doe 292 infinity-wall-art, Doe 293 Art4OursUS, Doe 294 AtikaDesign, Doe 295 AySuArtDesign, Doe 296 BestPrintStation, Doe 297 CanvasseurUK, Doe 298 DecorDelivery, Doe 299 DesignByPrint and Doe 300 DopePrintShop added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 301 FamousCanvasArt, Doe 302 FoenixArtStudio, Doe 303 FurryLandStudio, Doe 304 GnGBros, Doe 305 Hiddenjems, Doe 306 hotdoggraphictees, Doe 307 LewisEditing, Doe 308 lovelylittleprintsto, Doe 309 MagicEmbroideryTM, Doe 310 MinimalistRug, Doe 311 MyPremium, Doe 312 NikoleStudio, Doe 313 NiwoART, Doe 314 NomadiCanvasWallArt, Doe 315 PantherPrintArt, Doe 316 Pickartsso, Doe 317 PrintAtlas, Doe 318 PrintsWPersonality, Doe 319 SaltySallysShip, Doe 320 Sayitwellartprints, Doe 321 SpectrumArtDesigns, Doe 322 Spreeezy, Doe 323 TesDesignStore, Doe 324 Theflirtylobe and Doe 325 Thelabelady added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 326 TheUniverzal, Doe 327 WallArtsDecorShop, Doe 328 WallArtsPrints, Doe 329 WallTreasuresUK, Doe 330 WillowsFabricBlocks, Doe 331 5D Diamond Painting TOP, Doe 332 aimarula, Doe 333 ajkkj886, Doe 334 Aknzzknxsknxkxkjxxk cjzkn, Doe 335 AlanDye, Doe 336 chenpengling0667, Doe 337 chenshanyu1999, Doe 338 crr19950610, Doe 339 Darrylko, Doe 340 dhywihy, Doe 341 Dona laciura45, Doe 342 Eitjidfnskdnwontidnfsif hh49, Doe 343 ElsieZivqSsYeK, Doe 344 F6F6F65F, Doe 345 Francesllk, Doe 346 fuejewe, Doe 347 gaoqian1840, Doe 348 gengjiafeng54779, Doe 349 JacobCelestehXkQh and Doe 350 JJARTSHOP added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 351 Joanfu, Doe 352 Lg Petif, Doe 353 lin96670734, Doe 354 Linsey LaPlant, Doe 355 liping889, Doe 356 liuqing fashion, Doe 357 liuxu3597, Doe 358 Liyixiao521, Doe 359 llq666777, Doe 360 luofangmln123456, Doe 361 luoxiugui710, Doe 362 maolei4150, Doe 363 memgmengzezestore, Doe 364 Moment And Echo, Doe 365 nsuvouphvfmyhgn, Doe 366 qinqin123456, Doe 367 Skndkxkbxkxnkcnjxmb xkxj, Doe 368 Skndsmndmxmzmnzm znxams, Doe 369 Sofkskfksogndjfjsifhskf j69, Doe 370 sunhuili061205, Doe 371 SwinnDulwichyEJ, Doe 372 tianweicheng5612, Doe 373 TroyPeteoTtG, Doe 374 wangyumei999666 and Doe 375 WUruiyuan123456 added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 376 yanghaodong23979, Doe 377 yaomingfan, Doe 378 zhangfengqi123456, Doe 379 zhangxinrui, Doe 380 zhaojiashop, Doe 381 https://poshstudioz.myshopify.com, Doe 382 https://einhornhomewar es.com, Doe 383 https://thestylehabitat.com, Doe 384 https://theflirtylobe.com, Doe 385 https://pawcozi.com, Doe 386 https://www.canvasblac kart.com, Doe 387 https://www.madepants.com, Doe 388 https://www.mystylewears.com, Doe 389 www.postera.art, Doe 390 www.smileartdesign.com, Doe 391 www.bydesignstudiosco.com, Doe 392 www.sharingroomx.shop, Doe 393 weposters.com, Doe 394 ducicanvas.com, Doe 395 canvasfab.com, Doe 396 www.tallengestore.com, Doe 397 artisticafineart.com, Doe 398 popmotif.com and Doe 399 artsyfartsy.eu added to case caption. (Text entry; no document attached.)

NEW PARTIES: Doe 176 RUOPOTY Diamonds Painting Store, Doe 217 Shop911599394 Store and DOE 60 Colorful Cloud ART Store added to case caption. Terminating Doe 217 Shop911599394 Store, DOE 60 Colorful Cloud ART Store and Doe 176 RUOPOTY Diamonds Painting Store (Text entry; no document attached.)

MINUTE entry before the Honorable John Robert Blakey: On the Court's own motion, the 1/18/23 hearing on Plaintiff's motion for entry of default and default judgment 45 is stricken and reset to 2/1/23 at 11:00 a.m. in Courtroom 1203. Mailed notice

NOTICE of Voluntary Dismissal by Michael Moebius Dismissal of Doe No. 300

NOTICE of Voluntary Dismissal by Michael Moebius Dismissal of Doe No. 390

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissals [53] and [54], this case is dismissed with prejudice as to Defendants DopePrintShop and www.smileartdesign.com. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Based upon docket entry [51], it appears that summons was served 1/12/23, which would make any responsive pleading due 2/2/23. Accordingly, the Court denies without prejudice Plaintiff's motion for default and default judgment [45] and strikes the 2/1/23 motion hearing date. Mailed notice

DECLARATION of Theodore J. Chiacchio, Esq. Regarding Service of Process

Exhibit 1

MOTION by Plaintiff Michael Moebius for default judgment as to Renewed Motion for Entry of Default and Default Judgment

Memorandum in Support of Motion for Entry of Default and Default Judgment by Michael Moebius

(Supplement A)

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for default judgment 58 before Honorable John Robert Blakey on 2/8/2023 at 11:00 AM.

ANSWER to Complaint by Doe 315 PantherPrintArt

NOTICE of Voluntary Dismissal by Michael Moebius of DOE 313 NiwoART

MOTION by Plaintiff Michael Moebius for default judgment as to Second Renewed Motion for Entry of Default and Default Judgment

Memorandum in Support of Second Renewed Motion for Entry of Default and Default Judgment by Michael Moebius

Supplement A

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for default judgment[63] before Honorable John Robert Blakey on 2/15/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: In person motion hearing held on 2/8/2023. Plaintiff's motion for default [58] denied without prejudice. Counsel shall revise any proposed order as stated in open court and submit it to the Court by the close of business on 2/8/2023. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 62, this case is dismissed with prejudice as to Defendant NiwoART. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's submissions and, as discussed in court, the Court grants Plaintiff's second renewed motion 63 for default judgment as to the remaining Defendants who have not appeared or answered the complaint. Enter Order. Plaintiff shall file a status report by 3/3/23 concerning any remaining Defendants. The 2/15/23 Notice of Motion date is stricken. Mailed notice (gel,)

DEFAULT JUDGMENT ORDER Signed by the Honorable John Robert Blakey on 2/13/2023. Mailed notice(gel,)

NOTICE of Voluntary Dismissal by Michael Moebius Dismissal of Doe No. 318

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 70, this case is dismissed with prejudice as to Defendant PrintsWPersonality. Mailed notice

STATUS Report by Michael Moebius

MOTION by Defendant Doe 315 PantherPrintArt for extension of time to complete discovery

RESPONSE by Michael Moebiusin Opposition to MOTION by Defendant Doe 315 PantherPrintArt for extension of time to complete discovery [73]

RESPONSE by Michael Moebiusin Opposition to MOTION by Defendant Doe 315 PantherPrintArt for extension of time to complete discovery [73]

MOTION by Plaintiff Michael Moebius to withdraw response in opposition to motion[74]

MINUTE entry before the Honorable John Robert Blakey: The Court denies Defendant PantherPrintArt's motion to extend 73 for failing to comply with this Court's standing orders and Local Rules 5.3(b) and 37.2, strikes Plaintiff's responses 74, 75, and denies as moot Plaintiff's motion to withdraw 76. The parties shall meet and confer and work cooperatively in discovery. Mailed notice

MOTION by Plaintiff Michael Moebius for default judgment as to Doe Nos. 328, 377, and 386

Memorandum in Support of Motion for Entry of Default and Default Judgment Against Doe Nos. 328, 377, and 386 by Michael Moebius

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for default judgment 78 before Honorable John Robert Blakey on 3/29/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 3/29/2023. For reasons stated on the record, Plaintiff's motion for entry of default and default judgment against Doe Nos. 328, 377, and 386 [78] is denied without prejudice. Status hearing is set on 4/20/2023 at 11:00 a.m. in Courtroom 1203. Mailed notice

ATTORNEY Appearance for Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com by Jianyin Liu

ATTORNEY Appearance for Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com by Jianyin Liu Amended by Adding Email

MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com to vacate order[69], MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com for default judgment as to Doe 4 and Doe 387

Declaration Defendants' Declaration

Exhibit Exh. A - Feb. 9, 2023 Email

Exhibit Exh. B - Plaintiff's Initial Offer

Exhibit Exh. C - Screenshot of 1688.com Product

Exhibit Exh D - Paypal email and Amazon email

Exhibit Exh E - Madepants.com Contact Us

Exhibit Exh F - website customer service email

Exhibit Exh G - Amazon Record

MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com to vacate order 69 Amended

Declaration

Exhibit "A"

Exhibit "B"

Exhibit "C"

Exhibit "D"

Exhibit "E"

Exhibit "F"

Exhibit "G"

(Exhibit "H")

STIPULATION of Dismissal Dismissal of Doe No. 315

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the joint stipulation for dismissal 86, this case is dismissed with prejudice as to Defendant PantherPrintArt. Mailed notice

RESPONSE by Michael Moebiusin Opposition to MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com to vacate order 69 Amended 85

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F

Exhibit G

(Exhibit H)

REPLY by DOE 4 Madepants, Doe 387 https://www.madepants.com to response in opposition to motion, [88]

Declaration

Exhibit

Declaration

MINUTE entry before the Honorable John Robert Blakey: On 2/13/23, this Court entered a default judgment order as to numerous Defendants, including Defendants No. 4 and No. 387. See [69]. These Defendants have moved to vacate, see [84], [85]. Based upon its review of the docket and the parties' submissions, the Court denies the motion [84], [85]. Plaintiff served Defendants and they had actual notice of this lawsuit by at least 12/16/22 (indeed, the parties were negotiating a settlement at this time); yet these Defendants never appeared or responded to the complaint. Defendants argue that the affidavit concerning service of process is 'likely faulty"; yet they do not explain how or why this is so. Defendants concede that their attorney was negotiating a settlement with Plaintiff when the Court entered default judgment; they do not claim that the parties reached any agreement to resolve their dispute or otherwise agreed to extend the deadline for answering or appearing. In short, the docket reflects service of process and a complete failure to answer or otherwise appear in response to the complaint; thus far, Defendants have offered no factual or legal basis to vacate the default. To the extent the parties agreed to some resolution, Defendant should meet and confer with its counsel and Plaintiff and file an agreed motion to vacate the default judgment. The Court strikes the 4/20/23 status hearing date. Plaintiff shall file a status report by 4/28/23 concerning any remaining Defendants. Mailed notice

MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com for reconsideration regarding order on motion to vacate, order on motion for default judgment, text entry, [90]

RESPONSE by Michael Moebiusin Opposition to MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com for reconsideration regarding order on motion to vacate, order on motion for default judgment, text entry, [90] [91]

NOTICE by DOE 4 Madepants, Doe 387 https://www.madepants.com re MOTION by Defendants DOE 4 Madepants, Doe 387 https://www.madepants.com for reconsideration regarding order on motion to vacate, order on motion for default judgment, text entry, [90] [91] of Withdrawing Motion for Reconsider [DE 91]

FULL SATISFACTION of Judgment regarding order[69] Doe No. 4

FULL SATISFACTION of Judgment regarding order[69] Doe No. 387

MINUTE entry before the Honorable John Robert Blakey: The Court denies Defendants' motion for reconsideration 91, which argues that the Court erroneously applied certain factual findings to both Defendants, rather than just to Defendant 387. But Defendants' motion makes clear that the Court's findings concerning notice, in fact, apply to both Defendants. Indeed, Defendants jointly moved to vacate, jointly arguing all points on behalf of "Defendants" and discussing "Defendants' website https://madepants.com"; they state in their motion that they are "owned by the same owner, with their principal officers as Xuebo Zeng" and that "Defendants hired an attorney Ms. Chen in China from Fa-Shen Consulting to engage with the Plaintiff starting from early February of 2023, to negotiate the settlement with the opposing counsel." 85 at 5-6. Based upon these representations and assertions, the Court declines to reconsider its findings that these Defendants were served, had actual notice of this lawsuit, failed to answer or otherwise appear, and failed to provide any factual or legal basis to justify vacating the default. See 90. Mailed notice

STATUS Report by Michael Moebius

MOTION by Plaintiff Michael Moebius for default judgment as to Renewed Motion for Entry of Default and Default Judgment Against Doe Nos. 328, 377, and 386

Memorandum in Support of Renewed Motion for Entry of Default and Default Judgment Against Doe Nos. 328, 377, and 386 by Michael Moebius

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for default judgment 98 before Honorable John Robert Blakey on 5/10/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 5/10/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for default judgment as to Doe Defendants 328, 377 and 386 [98] is granted. Enter Default Judgement Order. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER Signed by the Honorable John Robert Blakey on 5/10/2023. Mailed notice

MOTION by Plaintiff Michael Moebius for release of bond obligation

NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for release of bond obligation[103] before Honorable John Robert Blakey on 5/24/2023 at 11:00 AM.

ORDER: The Court, having entered default judgment on May 10, 2023, herby grants Plaintiff's motion for release of bond 103, strikes the 5/24/23 Notice of Motion date, and releases the ten thousand dollar ($10,000.00) surety bond posted by Plaintiff on November 23, 2022. The Clerk of the Court shall return the surety bond previously deposited with the Clerk of the Court to Plaintiff or his counsel, Theodore Joseph Chiacchio, 307 North Michigan Avenue, Suite 2011, Chicago, IL 60601. Signed by the Honorable John Robert Blakey on 5/22/2023: Mailed notice.

ORDER Signed by the Honorable John Robert Blakey on 6/6/2023. Mailed notice

FULL SATISFACTION of Judgment regarding order 69 Doe No. 327

ATTORNEY Appearance for Defendant DOE 2 Laoife Direct by Zheng Gong

MOTION by Defendant DOE 2 Laoife Direct to set aside default MOTION TO VACATE DEFAULT JUDGMENT AND MOTION TO DISMISS AND TO RELEASE AND RETURN PROPERTY

Supplement Memorandum of Law in Support of Defendant's Motion to Vacate Def

Declaration Declaration_of_Defendant_in_support_of_Defendant's_Motion_to_Va

Exhibit Exhibit A to Declaration

Exhibit Exhibit B to Declaration

Exhibit Exhibit C to Declaration

Exhibit Exhibit D to Declaration

Exhibit Exhibit E to Declaration

NOTICE of Motion by Zheng Gong for presentment of motion to set aside default, [109] before Honorable John Robert Blakey on 2/21/2024 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: In this closed case, Defendant Laoife Direct recently appeared, see 108 and now seeks to vacate the default judgment order entered 5/10/23. See 109. But under Local Rule 83.12 "only members in good standing of the general bar of this Court may enter an appearance on behalf of a party; file pleadings, motions or other documents; sign stipulations; or receive payments upon judgments, decrees or orders. Defendant Laoife Direct's attorney, Zheng Gong, filed an appearance form that differs from the form available on the Court's website in that it omits the question of whether he is, in fact, a member of the general bar. As a result, the Court denies without prejudice the motion to vacate 109 and strikes the 2/21/24 Notice of Motion date. If this Defendant wishes to pursue the motion, its attorney must first file an updated appearance form that establishes compliance with the Local Rules. Mailed notice

ATTORNEY Appearance for Defendant DOE 2 Laoife Direct by Zheng Gong (Updated)

MOTION by Defendant DOE 2 Laoife Direct to set aside default

Declaration Declaration_of_Defendant_in_support_of_Defendant's_Motion_to_Vacate_Default_Judgment

Exhibit Exhibit A to Declaration

Exhibit Exhibit B to Declaration

Exhibit Exhibit C to Declaration

Exhibit Exhibit D to Declaration

Exhibit Exhibit E to Declaration

(Supplement Memorandum of Law in Support of Defendant's Motion to Vacate Default Judgment)

NOTICE of Motion by Zheng Gong for presentment of motion to set aside default, 113 before Honorable John Robert Blakey on 2/21/2024 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court takes under advisement Defendant Laoife Direct's motion to vacate 113 and strikes the 2/21/24 Notice of Motion date. Plaintiff shall respond to the motion by 2/29/24, and Defendant Laoife Direct shall file any reply by 3/7/24. Mailed notice

RESPONSE by Michael Moebiusin Opposition to MOTION by Defendant DOE 2 Laoife Direct to set aside default 113

Exhibit 1

(Exhibit 2)

REPLY by DOE 2 Laoife Direct to response in opposition to motion 116

Declaration

Exhibit A to the Supplemental Declaration

Exhibit B to the Supplemental Declaration

Exhibit C to the Supplemental Declaration

Exhibit D to the Supplemental Declaration

Exhibit E to the Supplemental Declaration

Exhibit F to the Supplemental Declaration

(Exhibit G to the Supplemental Declaration)

MINUTE entry before the Honorable John Robert Blakey: On 2/13/23, this Court entered a default judgment as to numerous defaulting Defendants, including Defendant Laoife Direct (No. 2). See 69. On 2/12/24, almost a year after judgment entered, Laoife moved to vacate the default judgment, see 109, 113 ; the Court denied the motion because Laoife's counsel failed to demonstrate compliance with Local Rule 83.12. Counsel remedied the deficiency and renewed the motion to vacate on 2/15/24, see 113. Laoife also asks the Court to dismiss the action for lack of personal jurisdiction and to enter an order requiring Plaintiff to return the seized and transferred funds, and requiring Amazon to remove all restrictions placed on Laoife's account as a result of the default judgment. Id. Plaintiff opposes the motion, see 116. Rule 60(b)(1) provides that "[o]n a motion and upon such terms as are just, the court may relieve a party. from a final judgment, order, or proceeding" upon a showing of "mistake, inadvertence, surprise, or excusable neglect." Fed.R.Civ.P. 60(b)(1); Jones v. Phipps, 39 F.3d 158, 162 (7th Cir. 1994). To prevail on its motion, Laoife must show: (1) "good cause" for the default; (2) quick action to correct the default; and (3) the existence of a meritorious defense to the original complaint. Id. (citing n. Pretzel & Stouffer v. Imperial Adjusters, 28 F.3d 42, 45 (7th Cir.1994); United States v. DiMucci, 879 F.2d 1488, 1495 (7th Cir.1989)). Laoife fails on all three requirements. Laoife's argue that it failed to monitor its only business email account; such neglect arguably remains inexcusable, particularly in light of its representation that it maintains a single valid business email and its concession that Plaintiff, in fact, provided actual notice of this lawsuit to that address. [113-1] at 2, 5-6. Moreover, even if the Court were to find Laoife's negligence excusable, Laoife still failed to take quick action to correct the default: even after Amazon restricted its funds, Laoife failed to even check its email for another seven months. Nor has Laoife demonstrated the existence of a meritorious defense; on the contrary, Laoife concedes that it offered infringing products on its Amazon site, concedes that it remained (at least until 10/10/22) ready, willing, and able to sell infringing products to residents of Illinois, and that it in fact sold an infringing product to a resident of Illinois. Plaintiff also challenges the damages awarded Plaintiff, arguing that it sold just one unit of the infringing product, resulting in an approximate profit of $0.50. Id. But the Court awarded Plaintiff statutory damages, which remain untethered to Defendant's sales or profits. For these reasons, the Court denies Laoife's motion to vacate and for other relief 113. This case remains closed. Mailed notice

NOTICE of Voluntary Dismissal by Michael Moebius Dismissal of Doe 2

MOTION by Plaintiff Michael Moebius Motion to Delete Docket Entry #119

Notice of Motion to Delete Docket Entry #119 NOTICE of Motion by Theodore Joseph Chiacchio for presentment of motion for miscellaneous relief 120 before Honorable John Robert Blakey on 4/24/2024 at 11:00 AM.

FULL SATISFACTION of Judgment Doe No. 2 (Laoife Direct)

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motion to delete docket entry 119, strikes the 4/24/24 Notice of Motion date, and directs the Clerk to remove this pleading from the docket. This case remains closed. Mailed notice.