2023-cv-02539

COMPLAINT filed by Sega Corporation, Sega of America, Inc.; Filing fee $ 402, receipt number AILNDC-20568798.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Schedule A regarding complaint 1 Modified on 6/6/2023.

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sega Corporation, Sega of America, Inc.

Notice of Claims Involving Trademarks by Sega Corporation, Sega of America, Inc.

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sameeul Haque

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Jeffrey Cummings. 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.)

MAILED trademark report to Patent Trademark Office, Alexandria VA (jk2,)

MAILED to plaintiff(s) counsel Lanham Mediation Program materials (jk2,)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 11

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

Exhibit 3-10

(Exhibit 3-11)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 14

Declaration of Martin F. Trainor

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 11, motion for miscellaneous relief 14, motion for miscellaneous relief 3 before Honorable John Robert Blakey on 5/10/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon the materials submitted, this Court grants Plaintiff's motion for leave to file under seal 3 and motion for electronic service of process 14, and strikes the 5/10/23 Notice of Motion date. The Court also grants Plaintiff's ex parte motion for entry of a temporary restraining order 11. Enter sealed temporary restraining order. Absent further order, this TRO will expire on 5/12/23. Mailed notice

TEMPORARY RESTRAINING ORDER: Signed by the Honorable John Robert Blakey on 4/28/2023. Mailed notice Modified on 6/6/2023.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

CIVIL BOND in the amount of $ 10,000 posted by Sega Corporation, Sega of America, Inc. (Document not Imaged).

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 20

(Declaration of Martin F. Trainor)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for miscellaneous relief 20 before Honorable John Robert Blakey on 5/10/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's ex parte motion 20 to extend the temporary restraining order entered 4/28/23 18. The Court finds that good cause exists to extend the temporary restraining order, and the order is hereby extended an additional fourteen days, to 5/26/23. The 5/10/23 Notice of Motion date is stricken. Mailed notice

SUMMONS Returned Executed by Sega Corporation, Sega of America, Inc. as to The Partnerships and Unincorporated Associations Identified On Schedule A on 5/19/2023, answer due 6/9/2023.

Declaration of Sameeul Haque

(Exhibit A)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for preliminary injunction

(Exhibit A)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for preliminary injunction 25

Declaration of Martin F. Trainor

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction 25 before Honorable John Robert Blakey on 5/24/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court takes Plaintiff's motion for preliminary injunction 25 under advisement, strikes the 5/24/23 Notice of Motion date, and sets the matter for hearing on 5/31/23 at 1:00 p.m. in Courtroom 1203. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 29, this case is dismissed with prejudice as to Defendants AKXIANGQIAOLIDIA NPU12 20, GDRHTFJ 35, sunstar2021 91, victory1848 92, zhanglanying6182 97, zhenzhen9981 98, wangsumeishop 179 and Zuisenyi 200. Mailed notice

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 5/31/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for preliminary injunction 25 is granted. Enter Preliminary Injunction Order. The Court directs the Clerk 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. Plaintiff may find instructions at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Status hearing set for 7/19/2023 at 11:00 a.m. in Courtroom 1203. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

PRELIMINARY INJUNCTION ORDER Signed by the Honorable John Robert Blakey on 6/5/2023. Mailed notice

NEW PARTIES: Changsha Zhouhang Technology Co., Ltd., Dongguan City Shijie Dongcheng Electronic Co., Ltd., Dongyang Chenchen Jewelry Factory, Fuzhou Jingchengcheng Trade Co., Ltd., Fuzhou PartyPlace Trading Co., Ltd., Guangzhou Leco Technology Co., Ltd., Hesper Import & Export (suzhou) Co., Ltd., Huizhou Junhui Electronic Commerce Co., Ltd., Jianou Jinbella Arts & Crafts Co., Ltd., Quanzhou Dexete Bag Co., Ltd., Shantou Qiye Toys Industry Co., Ltd., Shenzhen Longgang District Xr Electronics Factory, Shenzhen Poetry E-Commerce Co., Ltd., Shenzhen Yitu Electronics Co., Ltd., Yangzhou Wosen Toys Co., Ltd., Yiwu Binli Technology Co., Ltd., Yiwu Dun Shan Trading Co., Ltd., Yiwu Kaomikesi Jewelry Co., Ltd., Yiwu Xinmu Network Technology Co., Ltd., anduanqining, Bamboo's store, CHANGSHALIUYANGKEQINJINMAOYIYOUXIANGONGSI., ChangShaShiChiMaoShangMaoYouXianGongSi, chenxiaoqing023., chenyang5139, daijingwangjihaoszhoujiluoxian, daxiangmaoyihebeiyouxiangongsi, dingyanxinxikeji, dongguanshiyuyandianzishangwuyouxiangongsi, FASHION VV, ForexFun, GAOJIANYU, gaoshilongdedian, Guangzhou Siguniang E- Commerce Co. LTD, hanpengfeius, hbszzhsmyxgs, HiTME.law.pc, houshilong, JIA-TAO, jinanliuchengzhiyudianzishangmaoyouxiangongsi, jinanyuzhizhangriyongpinbaihuoyouxiangongsi, leixin(7-21 Delivery), LeWish, liangchangweiasdf, linzhilin1185, Liuyang Shisunyao Trading Co., Ltd., lixiadedian, LuYuFengVDWEHFISDKFNSD, NanChangJiMengPingShangWuKeJiYouXianGongSi, NXLTZ, Pamden, Putian Chengxiang District Fusuye Trade Co., Ltd, qiaoxiaolei, QSNQFWY, R-Cloud Trend, RazadaTech, shanxirangyodianzishangwuyouxiangongsi, SHOPNIC LTD, SHUHAO, Sonic Hoodies, STPTSSFMM, tiandachengyuyi, Tongshanxianshuangdaobaihuodian, Tongshanxianyanglanbaihuodian, wenzi, xin xinbaihuo, xuelinbo, Yio-us, YOYO TRADERS, A37ZKB4BQR4TRG, avaoomeek, buyerzoon2013, cht67cg_6, do205488, evelyn_shop01, gj68vff-8, hanf869, heyfriends_studio, honky_tonk_1, hzqzb3, mcchenchen, natah81, nid6_66, ruomumaoyi, vj68vh-4, wuxianqi_0, yahuuella8869, yangsh_3076, Baoding Mengshou Toy Co., Ltd., Dongguan Other-way Cap & Bag Manufactory Ltd, YC Gift (Zhongshan) Limited, CHATGPT, Esst shop, Godven, Haikou, Hzes, ILUGU, J0YBUY, JOYBDY-Direct, LOVELYSHOPPING, Ninety-nine, PINDUODUO, Quentin TECH, Shuangerxun E-Commerce Co.,Ltd., TEN10CENT, UNI STORE, unico.ltd, Yilimaizi, YXCC, 521xuruoxin1314, Bardhok, Bingrong Chen, chenenhui8967, chenrong1781, CHENXU1540, chuaihuishop, Cuieryong Babys, cvljq4shop, Dennis A McFadden, duancangbao76445, dumnhhey, ezsemjshop, f5dvc85, fanyuxin1716, fengzhekang, frnwos, furulei123, guogongqiangsd, Heatmindte, heconlianshop, Hhhhsh, hugaozhong, Hui Lei, huizepeijiao, HZHYU, KLDNKS, leiyuzhuwan, lianghao6, liangmiaoa, lihao9876, lijiagenhlj, lilinyishop, lin923923, LING YAN ANGANG Commodity Store, Lixianxu6664, lizhiwen668, Lori Chenard, lvxiao fashion, Math lesson teacher, Natbefy Canfey Lofilt, Online shoppingcmf, Peixiamuzi Bags, pengjinlong35641, pengminghiu9733r, ranyan, RongyuLi, sadhjasudhyusa, Sheri L Shackett, songbingbing9s9e3, sunpeipeishop, suruqiao, Taocomneir Toys, taozhisen, Tianrui Stationery, Toy Story, vrigri, wabwehay, wangqiudizuo, WANGXINGKK, weipeipeikn, wuhonglinshopstate, wuiyoutupang, wuzhongjun8747, XIANG123, Xiaojiang Foreign Trade Store, Xing bo shop, XIONGJIANGUO, XUEHUA123, yangguangqingqingxiaopu, yanghua520, yangxiaoqin321, yangyongyan2017, yuandibayue, zdd5546, zengchao5a, Zeropino Fikers pook, Zhangshaomin5080 and zhaozhiwenfang added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain Defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the notices of voluntary dismissal 31, 34, the Court hereby dismisses this case with prejudice as to Defendants Natural Behaviour (No. 52); Partypieces (No. 55); fazy887ji (No. 80); fourseaonbedding (No. 81); and Quentin TECH (No. 113). Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain Defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 36, this case is dismissed with prejudice as to Defendant SHUHAO. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 38, this case is dismissed with prejudice as to Defendants (39 HiTME.law.pc), (83 hanf869) and (104 Godvne). Mailed notice

NOTICE of Voluntary Dismissal by All Plaintiffs as to a certain defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 40, this case is dismissed with prejudice as to Defendant (87 mcchenchen). Mailed notice

MINUTE entry before the Honorable John Robert Blakey: The Court strikes the 7/19/23 status hearing date and orders Plaintiff to file a status report by 7/31/23 concerning any remaining Defendants. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 43, this case is dismissed with prejudice as to Defendants (SHOPNIC LTD 62); (xuelinbo 71); and (YOYO TRADERS 73). Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 45, this case is dismissed with prejudice as to Defendant (36 Guangzhou Siguniang E- Commerce Co. LTD). Mailed notice

STATUS Report by Sega Corporation, Sega of America, Inc.

(Exhibit A)

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain Defendant

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to approve consent judgment as to a certain Defendant (Agreed)

(Exhibit A)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion to approve consent judgment 49

(Exhibit 1)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendants with the Exception of Defendant YXCC

(Exhibit A)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, 51

Exhibit 1

(Exhibit 2)

DECLARATION of Martin F. Trainor regarding memorandum in support of motion 52

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, 51 before Honorable John Robert Blakey on 9/6/2023 at 11:00 AM.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon Plaintiff's notices of voluntary dismissal 48, 55, the Court hereby dismisses this case with prejudice as to Defendant ILUGU (No. 107) and without prejudice as to Defendant ForexFun (No. 32). Absent reinstatement by 3/5/24, this latter dismissal shall automatically convert to a dismissal with prejudice. The Court takes under advisement Plaintiff's motion for consent judgment as to Defendant YXCC (No. 119) 49 and directs Plaintiff to submit a proposed order as to this motion alone. The Court denies without prejudice Plaintiff's motion for default judgment 51, as it appears Plaintiff is still resolving matters with other Defendants. Plaintiff may renew the motion once it appears that all settlement negotiations are at an impasse. The 9/6/23 Notice of Motion date is stricken. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 57, this case is dismissed with prejudice as to Defendant (106 Hzes). Mailed notice

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sydney Paige Fenton

MOTION by Attorney Sameeul Haque to withdraw as attorney for Sega Corporation, Sega of America, Inc. No party information provided

NOTICE of Motion by Martin Francis Trainor for presentment of motion to withdraw as attorney 60 before Honorable John Robert Blakey on 9/20/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motion to withdraw the appearance of Sameeul Haque 60, strikes the 9/20/23 Notice of Motion date, and directs the Clerk to remove Attorney Haque from the docket in this case. Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

NOTICE by Sydney Paige Fenton of Change of Address

NOTICE by Martin Francis Trainor of Change of Address

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 63, this case is dismissed with prejudice as to Defendant (111 Ninety-nine). Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 67, this case is dismissed with prejudice as to Defendant (95 yahuuella8869). Mailed notice

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable John Robert Blakey: Based upon the filing of the notice of voluntary dismissal 69, this case is dismissed with prejudice as to Defendants (7 Hesper Import & Export (suzhou) Co., Ltd.) and (12 Shenzhen Longgang District Xr Electronics Factory). Mailed notice

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to approve consent judgment as to a certain Defendant (Agreed)

(Exhibit A)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion to approve consent judgment 71

(Exhibit 1)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendants with the Exception of Certain Defendants (Renewed)

(Exhibit A)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, 73

Exhibit 1

(Exhibit 2)

DECLARATION of Martin F. Trainor regarding memorandum in support of motion 74

(Exhibit 1)

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment, 73 before Honorable John Robert Blakey on 11/29/2023 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 11/29/2023. Defendants failed to appear and failed to notify Chambers of any scheduling conflicts. Plaintiff's motion for entry of default and default judgment 73 is granted. Enter Default Judgment Order. Civil case terminated. Mailed notice

JUDGMENT Signed by the Honorable John Robert Blakey on 11/29/2023. Mailed notice

MAILED trademark report to Patent Trademark Office, Alexandria VA.