2022-cv-06199

COMPLAINT filed by EnchantedMob, Inc.; Filing fee $ 402, receipt number AILNDC-20024667.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

EXHIBIT by Plaintiff EnchantedMob, Inc. Schedule A regarding complaint 1 Modified on 12/14/2022.

MOTION by Plaintiff EnchantedMob, Inc. for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by EnchantedMob, Inc.

ATTORNEY Appearance for Plaintiff EnchantedMob, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff EnchantedMob, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff EnchantedMob, Inc. by Kahlia Roe Halpern

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Jeffrey Cole. 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.

MAILED copyright report to Registrar, Washington DC.

MOTION by Plaintiff EnchantedMob, Inc. for temporary restraining order Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by EnchantedMob, Inc. in support of motion for temporary restraining order 10

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 11

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Zach Belanger regarding memorandum in support of motion 11

Exhibit 1

(Exhibit 2)

DECLARATION of Zach Belanger by Plaintiff EnchantedMob, Inc. Exhibit 3 - Parts 1-6 regarding declaration 13 Modified on 12/14/2022.

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

(Exhibit 3-6)

MOTION by Plaintiff EnchantedMob, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by EnchantedMob, Inc. in support of motion for miscellaneous relief 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process 3 10 15 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.

TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 11/14/2022. Notices mailed. Modified on 12/14/2022.

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

MOTION by Plaintiff EnchantedMob, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by EnchantedMob, Inc. in support of extension of time 20

(Declaration of Kahlia R. Halpern)

SURETY BOND in the amount of $50,000.00 posted by EnchantedMob, Inc. (Document not scanned).

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 20 is granted. The Temporary Restraining Order is extended to 12/12/22. Notices mailed.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain Defendants

MOTION by Plaintiff EnchantedMob, Inc. for preliminary injunction, MOTION by Plaintiff EnchantedMob, Inc. for extension of time of Temporary Restraining Order

(Exhibit A)

MEMORANDUM by EnchantedMob, Inc. in support of motion for preliminary injunction, extension of time 25

Declaration of Kahlia R. Halpern

(Exhibit 1)

SUMMONS Returned Executed by EnchantedMob, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/7/2022, answer due 12/28/2022.

Declaration of Kahlia R. Halpern

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 12/12/22. If no objections are filed, the motion will be considered unopposed. Counsel is advised that motions must now be noticed for presentment before Judge Shah on his scheduled motion call. Notices mailed.

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction, extension of time 25 before Honorable Manish S. Shah on 12/13/2022 at 09:45 AM.

EXHIBIT by Plaintiff EnchantedMob, Inc. Exhibit A regarding notice of motion 29

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain defendants

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 25 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. notice

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 12/13/2022. Notices mailed.

NEW PARTIES: Anqing Drainage Trading Co., LTD, Fuzhou Yibo Electronic Commerce Co., Ltd., Guigang Younger Craftwork Co., Ltd., Hebei Yerong Trading Company Ltd., Shenzhen Mertouch Technology Co., Limited, Taizhou beyda Outdoor Co., Ltd., Yiwu Hangwei Toys Firm, Yiwu Qiba Trading Firm, Yiwu Xingrong Crafts Co., Ltd., 3D Kids 3-14 Years Old Store Store, Autumn Fashion Children Clothing Store, Kieka Toy Dropshipping Store, LOVETTE DESIGN Store, Shenzhen Easinfinch Store, Shop1102155086 Store, Shop1102162187 Store, Shop1102174264 Store, Shop1102208952 Store, Shop1102246037 Store, Shop1102306443 Store, Shop1102318010 Store, Shop1102324015 Store, Shop1102327021 Store, Shop4393056 Store, Sonic Garden Collar Hoodie Store, Special Style Store, Strange lasagna Store, Yaya Sticker Store, ZHAN BAO ER Store, A1CJ36U9TIJ88E, A1DRS5LLTCT6UO, A1RP439F4U8Q35, A1ZY4A0FLC4ZO2, A2LF3TC4K1TTGW, A2S2UVQLLI4Z0B, A2TQO0EZ95EGNE, A3CCNV0NNQ74TM, A3H99VCLVH4GSX, A3MGML51A1NIJ0, A3ULLPJ2TK7T53, ADJW9VCQ1Y8KD, ANTHEA-Shop, ARRD5YVF986Q7, ASRWERSDF43TUYTIYUO, AXKKXWD6VQRFO, Bella funnyshop, BOBI SHOP, CARD GAME MASTER, Changsha Piyeli Electronic Commerce Co., Ltd., CMALL us, Crown Joker, DanZhouChiTangShangMaoYouXianGongSi, Eiffel toys, ELBJ-US-X, foshanshichanchengquqiqinghehuazhuangpinyouxiangon, foshansunkaimaoyiyouxiangongsi, foshanzhibinshangmaoyouxiangongsi, fuyangyangdebeimeidianpu, GDANNI, gongleidexiaodian, guosiyu11, guyu123, haitaodianpu, halloprops-US, hgffdrtrwewe, hnshkcyqsmyxgs, huangjingqiangdexiaodian, huichensuliao, jiahuabaihuo, JIAYSC2, JueCanTuDianZi, JXLC, lihuashangcheng, liqianyangyinshangmaoshanghang, Love from china, LUQTE, Maihaodao Shop, maokaiqi, mengwenbo123456, Nan Feng Xuan Qing Bai Huo Dian, NAUKY, NaZhaiYouDianZi, nianregannua5, nkdsnsl123, panjiezhen, Phaetona sqweph, PopyBag, putianchenningmaoyi example 1, PUWEIWEI, QattateaeraStore, shanxijingyakekejiyouxiangongsi, shencunchengjgfhr, SINUOSHANGMAOYOUXIANGONGSI, Store, SunYuDianZiShangWuYou8866, Tongshan County Liuzhe Convenience Store, wanzaixianyanqingbaihuo, wenchangzilinglankejiyouxiangongsi, wmagghlkd, wuleixiaopu, xianggangzhonghengyouxiangongsi, xiao lin shop, XIAOYUANSHENG, Xin Ao-US, xiuwenxianxiaohuishucaipifabu, yangjiaqing, yangling123, YCYYSMGS, YDN-AC, yuanshuaigaochuanmeiyouxiangongsi, YUBUYU, zengduqushanpaiyoubaihuodian, zengduquyulaihebaihuodian, ZENGZHEDEDIANPU, zhangjudebeimeidianpu, zhaoanxianbaiyangxiangshenyaocongjiancaishangdian, zhizun&lin, Zikud LCC., fadasdg, madmax_856, yahdirectstore, zhang-xiu, shaoxingyinchaofangzhipinyouxiangongsi, Shenzhen Guangyao Minghui Technology Co., Ltd, suzhouyihaishibeidianzishangwuyouxiangongsi, Wisdom Official Store and XUANYI added to case caption.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain defendants

ATTORNEY Appearance for Plaintiff EnchantedMob, Inc. by Quinn Bradley Guillermo

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain defendants

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.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain defendants

MOTION by Plaintiff EnchantedMob, Inc. for entry of default, MOTION by Plaintiff EnchantedMob, Inc. for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by EnchantedMob, Inc. in support of motion for entry of default, motion for default judgment 40

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 41

(Exhibit 1)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment 40 before Honorable Manish S. Shah on 1/17/2023 at 09:45 AM.

(Exhibit A)

NOTICE of Voluntary Dismissal by EnchantedMob, Inc. as to certain Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for entry of default judgment 40 is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 1/17/2023. Notices mailed.

FULL SATISFACTION of Judgment regarding order 46 in the amount of $50,000 as to certain defendant

NOTICE of withdrawal of bond 22 by John Summerfield. (Received for docketing 02/17/2023)

FULL SATISFACTION of Judgment regarding order 46 in the amount of $50,000 as to certain defendant