2023-cv-00720

COMPLAINT filed by Toho Co., Ltd.; Filing fee $ 402, receipt number AILNDC-20319095.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Toho Co., Ltd. Schedule A to Complaint (1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Toho Co., Ltd. by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Toho Co., Ltd. by Yanling Jiang

ATTORNEY Appearance for Plaintiff Toho Co., Ltd. by Yi Bu

ATTORNEY Appearance for Plaintiff Toho Co., Ltd. by Adam Grodman

ATTORNEY Appearance for Plaintiff Toho Co., Ltd. by Cameron Eugene Mcintyre

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Toho Co., Ltd.

CASE ASSIGNED to the Honorable Rebecca R. Pallmeyer. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. 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.

MOTION by Plaintiff Toho Co., Ltd. for leave to file under seal

MOTION by Plaintiff Toho Co., Ltd. for leave to file excess pages

MEMORANDUM in support of [12] Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Koji Ueda

Exhibit 1, of Koji Ueda's declaration

SEALED EXHIBIT by Plaintiff Toho Co., Ltd. Sealed Exhibit 2, Declaration of Koji Ueda regarding memorandum in support of motion, [13]

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for leave to file underseal [10] is granted. Plaintiff's motion to exceed page limitation [11] is granted. Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and or electronic publication [12] is granted. Emailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Rebecca R. Pallmeyer on 2/7/2023. Emailed copy to Plaintiff's counsel.

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

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

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

SURETY BOND in the amount of $10,000 posted by Toho Co., Ltd. (Document not scanned). Modified on 2/8/2023.

MOTION by Plaintiff Toho Co., Ltd. for preliminary injunction

MEMORANDUM by Toho Co., Ltd. in support of motion for preliminary injunction[20]

Declaration of Keith A. Vogt

Exhibit 1, Declaration of Keith Vogt

SUMMONS Returned Executed by Toho Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 2/15/2023, answer due 3/8/2023.

Declaration of Service

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for entry of a preliminary injunction [20] is granted. Order to enter. The Law Firms of Keith Vogt, Ltd. and Jiangip LLC are ordered to add all defendant names listed in Schedule A to the docket within three business days. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

NEW PARTIES: CreateenArtStudio, smallitems, ameer.store, anayesh-0, animeless, anjalin_86, ashwathora12, bannprema_0, berastore, bhjdnl, bou_5146, cgc_collections, colortoyz, danble-d123, dayafern18, directmar_0, dollar_deals_online_store, dream_line, drzau_24, ds_m_88, dsfsdgfvcxv66, dunguyent84, e-_like_house, falcon98_1, ganumadu0, gshopall, gskonl98, haibiao03, haikougudufanshan0, harindu519, heyang-model2, hongyeyuantu-86, km_makaara, lampbulbs2016-3, manel_online_store-1, masx_54897, minhuang8866, mohammadu_0, mumsrule2019 and pasmih-58 added to case caption.

NEW PARTIES: posterhall, pumart_89, qiuyuchen09, queensonlinestore, rizikr, sacmada-0, samaro-8448, shankusu, sharl28, shefern-4422, shen-store_4, sheper_9233, shub5633, silva9190, sincere_cosplay, sinekageek-73, singapkav0, sl-e-store, smartmidle, sucystore, theekshana_mart, theother_dox, thisaranjan-2, un_hubz, uniquethilina, very_001, vivia2048, vns_3559, vo4mer-64, whlly_09, wo2usunn26, wolongshop, worldshopgoco, xinjinkeji2022, xiu9704, xiyinyan_zhang, xulan_52, yingyue001, yiqingpp7, yjy-150, yjym-50, youd3308, yu108707, yuanfan_999, zha-6055, zhaoyu-20, zhengminghao8, Quanzhoushiqipandianzishangwuyouxiangongsi, AAA Distributions, AgemoArtShop, Ai-fun, Aiger Outdoor, AMZ-Furniture, bababeng, Bingguan1, BYLDD shop-us, Changsha Miao Chenwen Trading Co., Ltd., chibi mo hang baihuo dian, chibiduheshangmaoyouxiangongsi and Children Toy Mart(CTM) added to case caption.

NEW PARTIES: CUI-XINYI, CYAY, DanZhouJianWeiShangMaoYouXianGongSi, dawn rolph, eiqef, fe'fe, foshansuohengyamaoyiyouxiangongsi, GAN-JIANLIN, GaoLingZhuLingZhuWang and GToyCollection added to case caption.

NEW PARTIES: GuanZhenGui-shop, GUOJINGSHANGHANG, hahaliqipei, HaiKouShiYanFuShangMaoYouXianGongSi, haoshenghaitao, Hefei dantuan Network Technology Co., Ltd, Hefeichasangdianzishangwuyouxiangongsi, hegangshishiliedianzishangwuyouxiangongsi, hengdoushiyulandongdianzishangwuyouxiang, HNWJL, HUAQIZHUANMAI, HUI-SN, huishenghuobaihuo, huizhoudayawanhuamingjiadianweixiufuwubu, HYGGE HOME, JINGUOWEI, JinKaiRenFuJianCaiYouXianGongSi, K.Leblanc.LLC, KING-TY, KongXin-shop, KunMingLiWeiJunDianZiShangWuYouXianGongSi, kunmingyangangshangmaoyouxiangongsi, LBH toys, LiHaoNan-shop, Liu-Hi, LIU-Q, LIWENQING-SHOP, ljp ZY, longfengdianzishangwu, Luc666 Store, LYX-GSL, MASICONG, meijin, Mengbi, MengZhuang-shop, mjdd shop, Moemoe City, molilijp, Peak Desig and Plutooo added to case caption.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Rebecca R. Pallmeyer on 2/15/2023. Mailed notice.

NEW PARTIES: PTCMPW, PTZXq, qin., qingyuyudianzikeji, Red Manufacture, RENSMH, RUSSER, SABERS PLUSHTOYS, sdaffaer, sevenbaby7, sfugayfafa, shanxibujingkaiwangluokejiyouxiangongsi, shanxijiataitianchengshangmaoyouxianzhairengongsi, shenzhenshiluohuquweiyifushigongzuoshi, songshanqubotaibaihuodian, songyuanshixuyanshangmaoyouxiangongsi, SYFFSF, Tingman Electronics, Tinuan, US-ELIXIR Flagship Store, WANGLUNOOPSHOP, WangYaChao-shop, WDFHFGH4DGJFHJTUKI, WENC e-commerce, WLHONG, Womise, xiangxiaodongmaowu, XingYongFeng logowanie, XTUSHENG-US, yichangheenshangmaoyouxiangongsi8, yichangliangdangfengshangmaoyouxiangongsi, yunzhouyushang, Zeejh Lnt, ZGHNWW, zhangdongjie2022, zhangsuqi, ZhongKeZhiHuiJiaoYuZiXunYouXianGongSi, zhongshanshiougesaizhaomingyouxiangongsi, ZRhang, zsssu and Banen added to case caption.

NEW PARTIES: Beautiful Mind Co.,Ltd, BOYOUtoys, Everything You Need, hangzhoushuanghongbaozhuangyouxiangongsi, HaSlLuu Co. ltd, Home Solutions Co.,Ltd, Homekie, Laiqryptonian Technology Co., Ltd, Live Better, putianshilichengquhuazhengyemaoyiyouxiangongsi, Quintina, Shenzhenshi Mingqiaosidianzi Youxiangongsi, suzhoushilianluodianzishangwuyouxiangongsi, Toyella, Yao, Yezo, YILIDA STORE, YIWUSHIQIEQINDIANZISHANGWUYOUXIANGONGSI and Zhaotonglongchaodianzishangwuyouxiangongsi added to case caption.

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

MOTION by Plaintiff Toho Co., Ltd. for default judgment as to The Defendants Identified In The First Amended Schedule A

MEMORANDUM by Toho Co., Ltd. in support of motion for default judgment[26]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Rebecca R. Pallmeyer: The court sets the following briefing schedule for Plaintiff's motion for default judgment 26 as follows: Response is due by 3/22/2023 and reply is due by 3/29/2023. Mailed notice.

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

ATTORNEY Appearance for Defendant animeless by Adam Edward Urbanczyk

MOTION by Defendant animeless for extension of time UNOPPOSED

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Unopposed motion for extension of time [31] is granted. Defendant Animeless to file a response to Plaintiff's complaint by 4/5/23. Mailed notice.

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

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no 41 posterhall

ATTORNEY Appearance for Defendant BOYOUtoys by Adam Edward Urbanczyk

MOTION by Defendant BOYOUtoys for extension of time

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff's motion for entry of default and default judgment against the defendants identified in First Amended Schedule A [26] is granted. Order to enter. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Rebecca R. Pallmeyer on 3/30/2023. Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion for extension of time [37] is granted. Defendant BOYOUtoys to respond to Plaintiff's Complaint by 4/19/2023. Mailed notice.

MOTION by Defendant animeless for extension of time UNOPPOSED

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Unopposed motion for extension of time [41] is granted. Defendant Animeless to respond to plaintiff's complaint by 4/25/2023. Mailed notice.

SATISFACTION of Judgment as to defendant no. 65 uniquethilina

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 147 Moemoe City

MOTION by Defendant animeless for extension of time UNOPPOSED

MOTION by Plaintiff Toho Co., Ltd. for default judgment as to [Unopposed] Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendant BOYOUTOYS

MEMORANDUM by Toho Co., Ltd. in support of motion for default judgment[46]

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Unopposed Plaintiff's Motion for entry of default and default judgment against the defendant Boyoutoys [46] is granted. Order to enter. Mailed notice.

DEFAULT JUDGMENT ORDER as to BOYOUtoys: Signed by the Honorable Rebecca R. Pallmeyer on 5/2/202. Mailed notice.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Unopposed motion for extension of time [45] is granted. Defendant Animeless to respond to plaintiff's complaint by 5/16/23. Mailed notice.

MOTION by Defendant animeless for extension of time UNOPPOSED

MOTION by Defendant animeless to dismiss

Exhibit A

Exhibit B

Declaration of Qianjin Sun

Errata Unreported Opinions

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Motion to dismiss [52] is entered and continued for briefing. Plaintiff's response to be filed on or before June 20, 2023; reply, if any, due June 27, 2023. Motion for extension of time [51] is granted nunc pro tunc. Mailed notice.

MOTION by Defendant animeless Modify Preliminary Injunction Order [Dkt. 24], Emergency

Errata Unreported Opinions

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Plaintiff is directed to show cause by close of business tomorrow (June 9, 2023) why the asset freeze order should not be reduced to an amount not in excess of $5,000. Mailed notice.

Joint Notice Of Settlement With Plaintiff And Mooted Motion as to Defendant no. 5 animeless by Toho Co., Ltd.

MINUTE entry before the Honorable Rebecca R. Pallmeyer: As a result of a Joint Notice of Settlement being filed on 6/9/2023 56, the court strikes Defendant animeless' motion to dismiss 52 and emergency motion to modify asset restraint 54 without prejudice. Mailed notice.

STIPULATION of Dismissal Joint Stipulation of Dismissal as to Defendant No. 5 Animeless

MINUTE entry before the Honorable Rebecca R. Pallmeyer: Pursuant to the Joint Stipulation of Dismissal pertaining to the last remaining defendant Animeless, No. 5 [58], this defendant is dismissed without prejudice. Each party is to bear its own attorneys' fees, costs and expenses. Civil case terminated. Mailed notice.

SATISFACTION of Judgment as to defendant no. 179 XTUSHENG-US

SATISFACTION of Judgment as to defendant no. 197 BOYOUtoys