2022-cv-06203

COMPLAINT filed by Universal Music GmbH d/b/a Bravado; Filing fee $ 402, receipt number AILNDC-20024919.

Schedule A

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Yi Bu

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Adam Grodman

ATTORNEY Appearance for Plaintiff Universal Music GmbH d/b/a Bravado by Yanling Jiang

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Direct 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.

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Direct 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.

MEMORANDUM In Support of 7 Ex Parte Motion

Declaration of Keith A. Vogt

(Exhibit 1-2, Declaration of Keith Vogt)

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.

MINUTE entry before the Honorable Martha M. Pacold: For the reasons set forth in plaintiff's motion [7], the supporting memorandum [8] and the court's order, plaintiff's motion for leave to conduct expedited discovery and electronic service of process pursuant to Federal Rule of Civil Procedure 4(f)(3) [7] is granted.

ORDER For Leave to Conduct Expedited Discovery and Service of Process by E-Mail and/or Electronic Publication Signed by the Honorable Martha M. Pacold on 3/14/2023:

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

SUMMONS Returned Executed by Universal Music GmbH d/b/a Bravado as to The Partnerships and Unincorporated Associations Identified on Schedule A on 3/20/2023, answer due 4/10/2023.

(Declaration of Service)

MOTION by Plaintiff Universal Music GmbH d/b/a Bravado for default judgment as to The Defendants Identified In Schedule A

MEMORANDUM by Universal Music GmbH d/b/a Bravado in support of motion for default judgment[13]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

Declaration of Alexa Struck

MINUTE entry before the Honorable Martha M. Pacold: Any defendant objecting to plaintiff's motion for entry of default and default judgment 13 must enter an appearance and file a written objection by 4/20/2023. If no objections are filed, the court will consider the motion unopposed. Plaintiff shall serve defendants with this notice.

ORDER: No defendant has responded to plaintiff's motion for entry of default and default judgment 13. The motion 13 is granted. Based on the evidence submitted in support of the motion for entry of default and default judgment, and the admission of liability by virtue of the default, plaintiff has established that the infringement was willful, that damages should be awarded in the amount of $100,000 per defendant, and that a permanent injunction should be entered. Plaintiff has shown that the infringement of its marks causes it irreparable harm in the form of diminished goodwill and brand confidence, damage to plaintiff's reputation, loss of exclusivity, and loss of future sales; that monetary damages are inadequate to address these harms; and that the public interest would not be disserved by a permanent injunction. No defendant has appeared to argue otherwise, thus, the court also finds that the balance of the hardships favors an injunction. Enter Final Judgment Order. Terminate civil case. Signed by the Honorable Martha M. Pacold on 4/21/2023. Mailed notice

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Martha M. Pacold on 4/21/2023. Mailed notice