2023-cv-04688

COMPLAINT filed by Roblox Corporation; Jury Demand. Filing fee $ 402, receipt number AILNDC-20847135.

(Exhibit 1)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Roblox Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff Roblox Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff Roblox Corporation by Robert Payton Mcmurray

MOTION by Plaintiff Roblox Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff Roblox Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Roblox Corporation

CASE ASSIGNED to the Honorable Jeremy C. Daniel. Designated as Magistrate Judge the Honorable Sheila M. Finnegan. 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 Roblox Corporation for leave to file excess pages Plaintiff's Motion to Exceed Page Limitation

MOTION by Plaintiff Roblox Corporation for temporary restraining order 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

MEMORANDUM by Roblox Corporation in support of motion for temporary restraining order, 10

Declaration Bayley Declaration

Exhibit 1

Declaration Hierl Declaration

Exhibit Hierl Exhibit 1

Exhibit Hierl Exhibit 2

(Exhibit Hierl Exhibit 3)

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 1 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 2 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 3 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 4 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 5 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 6 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 7 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 8 of Bayley Declaration

SEALED DOCUMENT by Plaintiff Roblox Corporation Exhibit 2 Part 9 of Bayley Declaration

Notice of Claims Involving Trademarks by Roblox Corporation

NOTICE of Motion by Michael A. Hierl for presentment of motion for temporary restraining order, 10 before Honorable Jeremy C. Daniel on 7/26/2023 at 09:00 AM.

MAILED Trademark report to Patent Trademark Office, Alexandria VA

((List of Trademarks))

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

MINUTE entry before the Honorable Jeremy C. Daniel: The Court strikes the motion hearing set for 7/26/2023 and resets it to 8/2/2023 at 9:30 a.m. in Courtroom 1419. Mailed notice

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing held. Plaintiff's motion for leave to file under seal 6, motion for leave to file excess pages 9, and ex parte motion for a temporary restraining order 10 are granted. Enter Sealed Temporary Restraining Order. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Jeremy C. Daniel on 8/2/2023. Mailed notice

SURETY BOND in the amount of $ 10,000.00 posted by Roblox Corporation. (Document not scanned).

MOTION by Plaintiff Roblox Corporation for extension of time Plaintiff's Ex Parte motion to Extend the Temporary Restraining Order

MINUTE entry before the Honorable Jeremy C. Daniel: Plaintiff's ex-parte motion to extend the temporary restraining order 29 is granted. Mailed notice

MOTION by Plaintiff Roblox Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

MEMORANDUM by Roblox Corporation in support of motion for preliminary injunction 31

DECLARATION of Michael A. Hierl regarding motion for preliminary injunction 31

SUMMONS Issued as to Defendant The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

SUMMONS Returned Executed by Roblox Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 8/25/2023, answer due 9/15/2023.

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No.105

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 88

MOTION FOR MORE DEFINITE STATEMENT by Defendant Zhiyang Li.

RESPONSE by Zhiyang Li in Opposition to MOTION by Plaintiff Roblox Corporation for preliminary injunction Plaintiff's Motion for Entry of a Preliminary Injunction 31. (Exhibits)

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 147

MINUTE entry before the Honorable Jeremy C. Daniel: Motion for more definite statement 37 is entered and briefed as follows: plaintiff's response due by 9/27/2023; reply due by 10/4/2023. Court will rule by mail. Mailed notice

MINUTE entry before the Honorable Jeremy C. Daniel: Motion hearing regarding motion for preliminary injunction 31 set for 9/28/2023 at 9:30 a.m. Mailed notice

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 170, 200

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 145, 158

MOTION by Plaintiff Roblox Corporation for extension of time Plaintiff's Opposed Motion for a First Extension of Time to File a Response to Defendant's Motion for More Definite Statement [Dkt. No. 37]

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 74

RESPONSE by Plaintiff Roblox Corporation Plaintiff's Response to Defendant's Motion for a More Definite Statement [Dkt. No. 37]

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Jeremy C. Daniel on 9/28/2023. Motion hearing held. Plaintiff's motion for entry of a preliminary injunction 31 is granted. Plaintiff's motion for extension of time 44 is granted. Plaintiff's response due by 10/6/2023; reply due by 10/13/2023. The law firm of Hughes Socol PIers Resnick & Dym Ltd is hereby ordered to add ALL defendant names listed in the Schedule A to the docket within three business days, instructions can be found on the court's website located at www.ilnd.uscourts.gov/instructions. Mailed notice

NEW PARTIES: Almacenes Susy, AmosSallycTsZzB, cdsjhfdsfsf, Chipllys, jkdjhiydsdsxz, Lilyboom, nmjdskfyhsiuy, Puskisteck, ZhanxietanjI, CASEEX-US, danzhoushisimiaorankejiyouxiangongsi, foshanshichanchengquyijiyehuazhuangpinyouxiangongs, guangzhoujiaofeng, haikouanranxiaokejiyouxiangongsi, heniantian258baihuoshanghang, liuliweic, LuoYingSHJKLJHCKXJZIUVIZXZVZ, mingqindashuju, panhua123, ruantianxian, shilemin55baihuodian7523, sichuanyouliwenduojiaomaoyiyouxinagonsi, tanhaoxjyhs, tuxiamaoyi, wanzaixianwenlimiandianzishangwushanghang, Weifangcuiwanwangluokejiyouxiangongsi, WuYangSNACJKLJAKLFJSDAF, xinyishilinmiao, XuYuLiandddddddddd, yelinzbsvg, YLYWQQ, creativityboom, daisiyi998668, f5dvc85, Fitness proxuct, Guaragandabou, H huangxiuqin, HHMM001, hjh1996, Huanhuany, huizhinana, hukeyan2019, jiangxiusheng57137 and KanpayongjieEc added to case caption.

NEW PARTIES: kguofzw, liulan store, longguanhua49178, Lynsie, lzx22, mngzxkzozhlvvrpe, myideas, Richard Nelson, SJKBC JOXUS5151, Virginia M Greer, wangzitong7890, Waswsl, Weirlkk, wucaipingyu, xiayuanyuan1529, Xinpinyou, zhangchanchan4160, Zhangguihu6546, Zhangshaomin5080, ZHENGJUN2019, ZoeNatbTuBh, ZW2019, 1564968489, 22lianmingkangbaihuodian11, aixinliu, Akamok, AlaDing, ANDLU.AMZ, Aristino, AVSUAZ, BAOJQR, benrudianzi, BLNKLV LLC, Bombs, cangnanxianhoutianfazhipinyouxiangongsi, Cartoodie, catcatonline, Catsticker, CCGOLAN, Ceringcen, Changyeone, chenzan, Chjp Crafts, chongqingdenglifuzhuangyouxiangongsi, Cong Ty Bpo Bpo, CTHFA, cuijiahuiaw, Cute partydecoration, DOINB TIAN, dongguanshihaifushangmaoyouxiangongsi, duanhuanshangmao, enpaishengtaijiatingnongchang, escape.p, EYSON, Fcelery, fengyiyishang, foshanshichanchengqutianyiweifuzhuangyouxiangongsi, FuYangShiWanQiHaoDianZiShangWuYouXianGongSi, Goxbbity and Guangzhou Bozhan Trading Ltd. added to case caption.

NEW PARTIES: guangzhoushigengshengkejigongzuoshi1, HaErBinYinFengMaoYiYouXianGongSi, Haylynes, HELCT, hengyangshinanyuequaochenbaihuodian, HRH store, huansglibao, humengjunbaihuodian7865, HW-TG, HZB-Toys, jialie, jiangdngzzjd, jianghanshangmaoyouxiangongsi, Jiawei1, Jinanrongcunhulianwangyouxiangongsi, JinXiu1102, Kunming Cuhe Shangmao Youxian Gongsi, KYUHJU, Lanzyee, Lee Ang, leemur party, LGSKDJQR, libaochun123, lichengwangdexiaodian, likangningdedian, linjiangwei, linquanxianlianjunmaoyiyouxiangongsi, liufansggan, Liuyang Zexin Electronic Trading Co., Ltd., liuyutingcp, LSJJDYG, MAOYIYOUXIAN, Marcelle Legrand, Mentran US, mintforest, Mruo INC, MTMKQ, MuMan Health, New XYZ, nicetrade, niuboyingwangluokeji, North Latitude US, Nuoda, Obanai, Opalana, OuGanOuhuangdamai, PanHanC, PartyKKing, Pipishu, Pipocgo, QINQINHU SHOP, rangtongdianzi, Rexloend, Roback and run ya yuan taoci company limited added to case caption.

NEW PARTIES: sbifyasda, sccdymjssmyxgs, SHANXI TINGBEI DENGRE SHANGMAO YOUXIAN GONGSI, ShanXiFengErWenPuWangLuoKeJiYouXianGongSi, shanxiyanyihongwangluokejiyouxiangong, shemingbeimeidian, shen zi, splitraction, Styhoo, Sutbyk, SWEIZ, This is The Way Plush Shop, tianhuiweidedianpu, Tiwenny us, tobebigger, Vera - Sale, Vnzvs American Children's Toy Shop, WALKINTA-US, WangJidsfgchdhskjhfdshvixcsz, wangliyingdedian, wangminqiangde, wangshashakker, wangxiyudiangaisfhewnf, wangyingjiede, wantingshilulanmaoyiyouxiangongsi, Wings Flap, wuhanzhangsiqi, wujiaxinkl, XIAOSHI'S SHOP, XINJQR, XunFei, yangkuou, Yexujie, yinsanyun, Yiwushixiyulanmengjinchukoumaoyiyouxiangongsi, Yohikare, Yuan zhou qu yu xuan bai huo dian, yuelunshangmao, YunGongParty, yunsmart, yunxiaoxianyangroubaihuodian, Zagie, Zhang Yixue, zhangjunweii, Zhengshilongbaihuodian, zhongdexiaoyistore and ZMBMTKSS added to case caption.

NEW PARTIES: bcbi Store, ci6n Store, d4ca Store, db7g Store, dcvu Store, dhnu Store, dvhw Store, e9in Store, edhv Store, efqi Store, fi8x Store, ftyg Store, fuu2 Store, jauh Store, jwsd Store, krcq Store, lvlz Store, lwwn Store, m2r0 Store, nz2h Store, p2j2 Store, pgjp Store, pjessup2022 Store, ppy3 Store, r2cj Store, rhq1 Store, rpc4 Store, rrjg Store, rsui Store, seb2 Store, srbo Store, sxkv Store, szty Store, tai3 Store, topclass5a Store, udoi Store, x7kg Store, xhxv Store, ydft Store, ysdq Store, z1wh Store, zpfx Store, Hua Xin and Anqing Mawei Trading Co., Ltd. added to case caption.

NEW PARTIES: Almacenes Susy, AmosSallycTsZzB, cdsjhfdsfsf, Chipllys, jkdjhiydsdsxz, Lilyboom, nmjdskfyhsiuy, Puskisteck, ZhanxietanjI, CASEEX-US, danzhoushisimiaorankejiyouxiangongsi, foshanshichanchengquyijiyehuazhuangpinyouxiangongs, guangzhoujiaofeng, haikouanranxiaokejiyouxiangongsi, heniantian258baihuoshanghang, liuliweic, LuoYingSHJKLJHCKXJZIUVIZXZVZ, mingqindashuju, panhua123, ruantianxian, shilemin55baihuodian7523, sichuanyouliwenduojiaomaoyiyouxinagonsi, tanhaoxjyhs, tuxiamaoyi, wanzaixianwenlimiandianzishangwushanghang, Weifangcuiwanwangluokejiyouxiangongsi, WuYangSNACJKLJAKLFJSDAF, xinyishilinmiao, XuYuLiandddddddddd, yelinzbsvg, YLYWQQ, creativityboom, daisiyi998668, f5dvc85, Fitness proxuct, Guaragandabou, H huangxiuqin, HHMM001, hjh1996, Huanhuany, huizhinana, hukeyan2019, jiangxiusheng57137 and KanpayongjieEc added to case caption.

REPLY by Plaintiff Roblox Corporation Plaintiff's Reply in Support of Entry of Preliminary Injunction

DECLARATION of William B. Kalbac Declaration of Service

MOTION by Plaintiff Roblox Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against the Defendants Identified in Amended Schedule A

(Exhibit A)

MEMORANDUM by Roblox Corporation in support of motion for default judgment, 50

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment, 50

(Exhibit Hierl Exhibit 1)

ATTORNEY Appearance for Defendants Wings Flap, Zagie by Brian Swift

MOTION by Defendants Wings Flap, Zagie for extension of time to file answer

DEFENDANT'S MOTION TO WITHDRAW MOTION FOR MORE DEFINITE STATEMENT AND RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION FOR ENTRY OF A PRELIMINARY INJUNCTION.

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 169

MINUTE entry before the Honorable Jeremy C. Daniel: Defendant's motion to withdraw pending motion 55 is granted. Defendant's motion for a more definite statement 37 is denied as withdrawn. Motion for extension of time to answer 54 is granted. Defendants response to plaintiff's complaint is due on or before October 31, 2023. Mailed notice

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 100, 148, 154

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 174

ATTORNEY Appearance for Defendants Wings Flap, Zagie by Adam Edward Urbanczyk

MOTION by Defendants Wings Flap, Zagie for extension of time UNOPPOSED in-part

MINUTE entry before the Honorable Jeremy C. Daniel: The defendants' motion for an extension of time to answer or otherwise plead is granted [62]. The defendant shall answer or otherwise plead on or before November 21, 2023. No further extensions will be granted. Mailed notice

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 76, 82

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 75

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 162

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendants No. 78, 160, 201

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 12/28/2023: Mailed notice.

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 127

NOTICE of Motion by Michael A. Hierl for presentment of motion for default judgment, 50 before Honorable Jeremy C. Daniel on 1/31/2024 at 09:30 AM.

NOTICE of Voluntary Dismissal by Roblox Corporation Plaintiff's Notice of Voluntary Dismissal as to Defendant No. 130

FINAL JUDGMENT ORDER. Signed by the Honorable Jeremy C. Daniel on 1/31/2024. Motion hearing held. Plaintiff's motion for entry of default judgment against defendants identified in Amended Schedule A 50 is granted. Civil case terminated. Mailed notice

SATISFACTION of Judgment

MINUTE entry before the Honorable Jeremy C. Daniel: Any party to this action has until October 3, 2025, to justify the continued need to seal any documents in this case. The Court intends to unseal all documents in this case after that date. Mailed notice.

STATUS Report by Roblox Corporation

STATUS Report Revised Status Report by Roblox Corporation

MINUTE entry before the Honorable Jeremy C. Daniel: The Clerk is directed to unseal all sealed documents. Mailed notice.