2023-cv-02009

COMPLAINT filed by Bryan Fletcher, Garrett Fletcher; Filing fee $ 402, receipt number AILNDC-20492937.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Schedule A regarding complaint[1]

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for leave to file under seal

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiffs Bryan Fletcher, Garrett Fletcher by Trevor Christian Talhami

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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 Plaintiffs Bryan Fletcher, Garrett Fletcher for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for temporary restraining order 9

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 10

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Steve Fletcher regarding memorandum in support of motion 10

(Exhibit 1)

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Exhibit 2 - Parts 1 - 8 regarding declaration 12

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

Exhibit 2-5

Exhibit 2-6

Exhibit 2-7

(Exhibit 2-8)

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for miscellaneous relief 14

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 15

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for temporary restraining order 9, motion for leave to file 3, motion for miscellaneous relief 14 before Honorable Manish S. Shah on 4/5/2023 at 09:45 AM.

MAILED copyright report to Registrar, Washington DC

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] [9] [14] 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 4/4/2023. Notices mailed.

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

INJUNCTION BOND in the amount of $ $50,000.00 posted by Bryan Fletcher, Garrett Fletcher. (Document not scanned).

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for preliminary injunction 22

Declaration of Justin T. Joseph

(Exhibit 1)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for preliminary injunction 22 before Honorable Manish S. Shah on 4/18/2023 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/13/2023, answer due 5/4/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for preliminary injunction [22] is granted. Enter Preliminary Injunction Order. 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 4/18/2023. Notices mailed.

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/19/2023, answer due 5/10/2023.

Declaration of Trevor C. Talhami

Exhibit A

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

NEW PARTIES: Bandai Direct Operation Store, Biscuit toy Store, Blue Cool Toy Store Store, BOOKFONG Official Store, Brainstorm-4 Store, Changjiang Store, Creative Holiday Gifts Store, DreamsIsland Store, Festive & Party Supplies Store, Fun gift shop Store, Kids-Toy Store, New Kid toy world Store, Peripheral animation Store, Plush Doll Exclusive Shop Store, Shop1102158823 Store, Shop1102513078 Store, Shop1102531069 Store, TAKARATOMY Toy Fun City Store, Toy House 2021 Store, Toyub Baby Store, Uncle Tomato Store, Win-Win Toy Store, Zoeybaby Store, A239TIDSGH4N45, A3IURNY84IYN05, A3TGFPD662ROV0, Amaaxy, AmzKangan, Aqrfewyeterast4gwerf, AQSNZ US, babyhoome, cartoonTEE-studio, catcatonline, CHANGHONGSHANGWU, Changsha Luhe Miao Trading Co., Ltd., congsh, COOL Backpacks, danzhouzhouchangjunkejiyouxiangongsi, DouJiaKeJi, fangjie shipp, Geluviay, haikoushiyuzeshangmaoyouxiangongsi, hanshouxianhuizhibaihuodian, HOMY-US, HXMIN, Ironclad soldiers outdoors, kuailedeshangdian125, liaomaoguang, liuyangyangkj, MakotoH, MAO ZHU, MarkerTrade, Minuo, Mruo INC, Oush, Project management of diyuan construction, putianshichengxiangquruidishiyanjingdian, Puxin, shanghaihuanmowenhuachuanmeiyouxiangongsi, shanxishuailianwangluokejiyouxiangongsi, shijiazhuangshichanganqushifanglu5hao, syhymx, TRYCHIC STATIONERY, US-7-14 days, WangYaSenShanXiDaJiAi, Wbxwtrypd, Wubaochun, xishuangbannaminranwangluokejiyouxiangong si, XK-Life Direct, xuhcymxd, Xukpeng, XXIEE, yasiniyakupu, yiliangmichu, yiwushiyingyumaoyiyouxiangongsi, Yixin US, yongchunxiandoudouwangloukejiyouxiangongsi, yuanhaoran s, Yuchenstores, yueliangzhishangyin, YUHIDAW, yujie store, yunxiaoxiantongmeibaihuodian, zhaoxianguang, Zhengrongfeng, ZUZU BOOM, balbosa, Boyuancase, dang08, fashionstype, guan009, Huan08, ineluls Store, jescakoo, Jyfybaby, lababy, limengxin1984, Luoluoc8888, Mic518, Molik, PDD Store, Smyy6, smyy7, super_hunter111 Store, surprise_store922 Store, toyshopping2021, Yfygirl001, zlnewhome, Znc_store, Zwl1314, chengl_6082, cymstore, dexin668, dzhstore, gaadejx-76, hongkongfa-0, marks.store, ruler-2013, xinsirui_6, zhongwe3, AMZXMAS, BEIYOYO INC, BLUE WHALE Store, Cockroach, COOGOU, Display name, gaoyixian, Ge Bo La Ke Ji, GUGUELEC, HNB BEAUTY INSTRUMENTS, jihangmaoyi, Kaulbiat, King of Diy, Maanshan Shiduoba, mengchengxianhehuashangmaoyouxiangongsi, nanningwanruisaisheng, NTDUEE, NuanYu US, putianfangyimaoyiyouxiangongsi, Roivhiui Co. ltd, RR Co.ltd, shangjuemaoyi, Shenzhen Mengwei Technology Co., Ltd, St. Patrick's Store, Tiger, UAEHWK, wangwenjiefanwenhuayishu, xiamenzhengfengkenwangluo, XianYouJuanHanMaoYi, Yiwu Xinchang E-Commerce Co., Ltd, Yoyo-Home, Zyyyds, AmeliaWendelldQtP, Anime Family K, boulangerre, bthfgh, Churuya Online, CNNSSK, Comands Electrics Market, DietThank, dingmengying4443, Emma1214, frog dollhouse 1, HARM, HUANGRONGRUIL, JerryPaulagQcWwD, Lara Orka, LUCIJOP, maer, MyLovely, Psicroptic, Sweet17, The House Of Special Store, wuzhongjun8747, Xu Xiaoyu graffiti stickers, yaotianxiang5499, yuzhuangy, zhaomengting0865, zhenchangjian5352 and zhuzhongqing3215 added to case caption.

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

NOTICE of Voluntary Dismissal by Bryan Fletcher, Garrett Fletcher as to certain defendants

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for entry of default, MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher for default judgment as to all Defendants

(Exhibit A)

MEMORANDUM by Bryan Fletcher, Garrett Fletcher in support of motion for entry of default, motion for default judgment, 33

(Exhibit 1)

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 34

(Exhibit 1)

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher to approve consent judgment as to Defendant No. 128

(Exhibit A)

NOTICE of Motion by Justin Tyler Joseph for presentment of motion to approve consent judgment 36, motion for entry of default, motion for default judgment, 33 before Honorable Manish S. Shah on 5/17/2023 at 09:45 AM.

(Exhibit A)

ATTORNEY Appearance for Defendant UAEHWK by Adam Edward Urbanczyk

MOTION by Defendant UAEHWK for extension of time

ATTORNEY Appearance for Defendant Display name by Adam Edward Urbanczyk

MOTION by Defendant Display name for extension of time

ATTORNEY Appearance for Defendants Display name, UAEHWK by Brian Swift

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motions by defendants UAEHWK [39] and Display name [41] for extensions of time are granted, and both defendants must respond to the complaint by 6/5/23. By 6/8/23, the parties shall submit a status report with a proposed case schedule as to those defendants. The plaintiffs' motion for entry of default judgment [33], modified to exclude defendants UAEHWK and Display name is granted. Enter Default Judgment Order. The motion to approve consent judgment [36] is granted. Enter Consent Judgment. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 5/17/2023. Notices mailed.

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 5/17/2023. Notices mailed.

FULL SATISFACTION of Judgment regarding order[44] in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[44] in the amount of $50,000 as to certain defendants

MOTION by Defendants Display name, UAEHWK for extension of time to file answer

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer [48] is granted. Defendants Display Name and UAEHWK have until 6/19/23 to respond to the complaint. Notices mailed.

MOTION by Plaintiffs Bryan Fletcher, Garrett Fletcher to approve consent judgment as to Defendant Nos. 126 and 146

STATUS Report per [43] by Bryan Fletcher, Garrett Fletcher

FULL SATISFACTION of Judgment regarding order[44] in the amount of $50,000 as to certain defendants

CONSENT JUDGMENT. Signed by the Honorable Manish S. Shah on 6/8/2023: The motion to approve consent judgment [50] is granted. Civil case terminated. Notices mailed.

FULL SATISFACTION of Judgment regarding order[44] in the amount of $50,000 as to certain defendant

NOTICE of Removal of Material from the Custody of the Clerk's Office Injunction Bond [21] in the amount of $50,000.00 posted by Bryan Fletcher, Garrett Fletcher. (Attachment)

FULL SATISFACTION of Judgment regarding order 44 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 44 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 44 in the amount of $50,000 as to certain defendants