2023-cv-04324

COMPLAINT filed by Bryan Fletcher, Garrett Fletcher; Filing fee $ 402, receipt number AILNDC-20802942.

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 Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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 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 10

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

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Steve Fletcher regarding memorandum in support of motion 11

(Exhibit 1)

SEALED EXHIBIT by Plaintiffs Bryan Fletcher, Garrett Fletcher Exhibit 2 - Parts 1 - 5 regarding declaration 13

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

(Exhibit 2-5)

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 15

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

Exhibit 1

(Exhibit 2)

SURETY BOND in the amount of $ 10,000 posted by Bryan Fletcher, Garrett Fletcher. (Document not Scanned)

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

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 21

Declaration of Justin T. Joseph

(Exhibit 1)

SUMMONS Returned Executed by Bryan Fletcher, Garrett Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 7/21/2023, answer due 8/11/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 21 for entry of a preliminary injunction. In connection with that motion, Plaintiff must serve all Defendants with the following statement: "The Court has taken the motion for a preliminary injunction under advisement and will consider the motion unopposed if no Defendant appears and objects by July 31, 2023. If no objections are filed by that date, the Court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiffs Bryan Fletcher, Garrett Fletcher per 24

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: Plaintiff's motion for a preliminary injunction [21] is granted. Plaintiff's filings establish that it has acted expeditiously to protect its interests and that there remains a significant risk Defendants will transfer relevant assets beyond the Court's reach. For these reasons, as well as the reasons provided in the whole of Plaintiff's filings and as stated by the Court in connection with entry of the TRO, the Court is persuaded that Plaintiff has satisfied the requirements for a preliminary injunction. In addition, the Court finds that the balance of harms favors Plaintiff and that a preliminary injunction serves the public interest by, among other things, protecting consumers from the marketing of counterfeit goods. Plaintiff has also certified and established [25] that it provided electronic notice to defendants of the pendency of this case and provided a link to a website containing relevant case documents, but no objection to the motion for a preliminary injunction has been filed on behalf of any defendant. Enter preliminary injunction order. Plaintiff's counsel is directed to ensure that all defendants listed on Schedule A are added to the court's docket within five business days. The Clerk shall unseal any documents that are sealed. The Law Firm of Greer, Burns & Crain, Ltd., is ordered to add ALL defendant names listed in the Schedule A to the docket within five business days, instructions can be found on the Court's website at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Lindsay C. Jenkins on 8/2/2023. Mailed notice.

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

NEW PARTIES: A pleasant trip Store, Anju Fashion Home Textiles 3 Store, Anju Fashion Home Textiles 6 Store, Anju Fashion Home Textiles 8 Store Store, Brilliant Fun Party Store, Brilliant Trip Store, ChildrenLife Store, CYXW Store, Dear friend stickers Store, Factory Starts to Sell Online Store, FAFAFREE Store, GGYY Store, JACK WALL DEC Store, L-PD-5 Store, Lucky Tiger Store Store, Meiyidakuajing Store, Mi 3 Store, Otisbaby Store, Printly studios Store, Shop1102786856 Store, Shop1102809030 Store, Short Uncles Store Store, Stickers Emotions Store, Toy Aholic Store, Toy Day Store, Un Nameable Toy Store, U-party Store, Xiao Zhou toy Store, AAHR80EL3O37Q, asbdyuqgfdgqqweqwe, bijwqebiugq, Catsticker, CCD LLC, chengmaixun, chenzan, CHUANCHENGJIAJU, FU JIE J, fuaibaihuo, GuoDongShengUS, haikouyuzhengmaoyiyouxianzerengongsi, hanhongyudedianpu, HeefA LLC, hiping-us, huangqiminhg, HurenmingUS, HutaoUS, jiujiangchensayi, JUNJIEJIE, LanBaoT, lijunjiegywsgh, Liu Zixing, LiuHaoUS, Manmiao, MARY SHORE, mayanjundianpu, MingLi Lan, New XYZ, Qlshs, shanxifenglangyuanlianshangmaoyouxiangongsi, songyuanshijiahuikejiyouxiangongsi, TigeeeeR, Tors, Wanzaixiantihuobaihuodian, WhiteT, XiakiCun, XIE-MANHONG, yangrongrongmeironghulidian, yansgyunheng, YBDZSW, yingshengshangmaoyouxiangongsi, ZZHLY, aiwatradingtoysgifts, Betty Sublimation, elapp, flowery888, good_for_life, jamesok, long10, meck, nbajerseys2023, paco_cha, qwas584, SOGOOD, sts_013, sunmouldcompanyltd, us_california, us_oregon, anqingfafushang0, hmlb2226429yo6, huading90, ryjlb380nadc6, wuzhen568, Anhui YSW F&T Media, Anahilly Toys, Barry Alboum, California Clutch & Gear, cuixiaoyi1196, dec-LIFE-cor, Erfan Ghavampour, Evans Would Fashion, guozhichuangshi, huanhxhay, jianpengbo9990, liuchao886699, qingzhulongsheng, Tesorero, Wang Song Shop, weiudyrhru, Wild Bunch, XiaMen Lebo LTD, zhanghongqun; and zhaoshilans added to case caption.

SUMMONS Returned Executed by Garrett Fletcher, Bryan Fletcher as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/4/2023, answer due 8/25/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

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, [32]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[33]

Exhibit 1

MINUTE entry before the Honorable Lindsay C. Jenkins: Before the Court is Plaintiff's motion 32 for entry of default and default judgment against all Defendants. All remaining defendants have failed either to plead or to otherwise appear to defend against this action. Accordingly, default is entered under Rule 55(a) of the Federal Rules of Civil Procedure. Any objections to the motion for entry of default judgment must be filed on or before September 7, 2023. If no objections are filed by that date, the court will consider the motion unopposed. Plaintiff must serve this minute order upon all remaining Defendants within one business day of its entry on the docket and must promptly file proof of that service. Mailed notice.

CERTIFICATE of Service by Plaintiffs Bryan Fletcher, Garrett Fletcher per 35

(Exhibit A)

MINUTE entry before the Honorable Lindsay C. Jenkins: No remaining Defendant has responded to Plaintiff's motion for entry of default judgment. Accordingly, the motion 32 is granted. Based on the evidence previously submitted by Plaintiff and the admission of liability by virtue of the default, Plaintiff has established that a permanent injunction should be entered. The infringement of Plaintiff's copyrights irreparably harms Plaintiff and confuses the public. This infringement was willful and statutory damages are awarded. After considering the nature of the products, the price point, the absence of any concrete evidence of lost profits or high-volume infringement by Defendants, the value of Plaintiff's brand, and the need to deter infringement that is easily committed and difficult to stop, the court concludes that $100,000 is an appropriate award of statutory damages. Enter Final Judgment Order. Civil case terminated. Mailed notice.

ENTERED JUDGMENT Signed by the Honorable Lindsay C. Jenkins on 9/8/2023. Mailed notice.

FULL SATISFACTION of Judgment regarding entered judgment 38 in the amount of $100,000 as to certain defendants

NOTICE of Removal Material from the Custody of the Clerk's Office by Justin R. Gaudio, firm Greer Burns & Crain Ltd by the Plaintiff regarding Bond 20. (Received for Docketing on 12/11/2023)