2023-cv-04707

COMPLAINT filed by Crypton Future Media, Inc.; Filing fee $ 402, receipt number AILNDC-20851252.

Exhibit A

MOTION by Plaintiff Crypton Future Media, Inc. for Leave to File Certain Documents Under Seal

MAILED Trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

AMENDED complaint by Crypton Future Media, Inc. against The Partnerships and Unincorporated Associations Identified on Schedule A

(Exhibit A)

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable M. David Weisman. 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.

SEALED EXHIBIT by Plaintiff Crypton Future Media, Inc. Schedule A to Amended Complaint regarding amended complaint 9

ATTORNEY Appearance for Plaintiff Crypton Future Media, Inc. by Matthew L. De Preter (De Preter, Matthew)

MOTION by Plaintiff Crypton Future Media, Inc. for temporary restraining order

MEMORANDUM by Crypton Future Media, Inc. in support of motion for temporary restraining order 12

Declaration of Stewart Miller

(Exhibit A)

SEALED EXHIBIT by Plaintiff Crypton Future Media, Inc. Exhibit 2 - Evidence regarding memorandum in support of motion 13

NOTICE of Motion by Sofia Quezada for presentment of motion for temporary restraining order 12, motion for miscellaneous relief 4 before Honorable Edmond E. Chang on 8/9/2023 at 08:30 AM.

MOTION by Plaintiff Crypton Future Media, Inc. for Electronic Service of Process

Supplement Memorandum in Support

(Declaration of Matthew De Preter)

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion 12 for temporary restraining order and other relief is granted. An order will be entered under seal separately. Although the Court again expresses its concern about restraining assets before judgment, Grupo Mexicano de Desarrollo v. Alliance Bond Fund, 527 U.S. 308, 331 (1999), the Plaintiff does invoke a statutory remedy, namely, an accounting of profits (that is, disgorgement of profits) under 15 U.S.C. § 1117(a), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, trademark owners need only "prove defendant's sales only; defendant must prove all elements of costs or deduction claimed." 15 U.S.C. § 1117(a). To the extent that the restraint might be too broad, the Defendants may appear and file challenges to the scope of the TRO. The balance of factors tips in favor of Plaintiff being able to freeze the assets without advance warning to the Defendant, who likely would seek to transfer the money elsewhere. The Plaintiff's motion 4 for leave to file under seal is granted in light of the asset-restraint goal. By 08/11/2023, the Plaintiff shall email to the Proposed Order account a redacted version of the TRO that can be entered publicly (redacting the names of Defendants and omitting Amended Schedule A). The Plaintiff's motion 16 for electronic service of process is granted. To track the case only (no appearance is required, the case will not be called), a status hearing is set for 08/18/2023 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 08/15/2023. Mailed notice

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Edmond E. Chang on 8/8/2023.

REDACTED SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 08/08/2023. Emailed notice

MOTION by Plaintiff Crypton Future Media, Inc. for Leave to Deposit Bond Via Law Firm Check, or Alternatively, for Extension of Time to Deposit Bond

MINUTE entry before the Honorable Edmond E. Chang: The Plaintiff's motion on the bond 19 is granted in part and denied in part. A law-firm check is insufficient. The deadline to post the cash or surety bond is extended to 08/22/2023. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The tracking status hearing of 08/18/2023 is reset to 08/25/2023 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Emailed notice

money order BOND in the amount of $ 1000 posted recipet 4624289913 by Crypton Future Media, Inc.

MOTION by Plaintiff Crypton Future Media, Inc. for extension of time for Temporary Restraining Order

Supplement Memorandum in Support

(Declaration of Sofia Quezada Hastings)(Quezada Hastings, Sofia)

REGISTRY DEPOSIT INFORMATION FORM by Crypton Future Media, Inc.

MINUTE entry before the Honorable Edmond E. Chang: In light of the circumstances that justified entry of the initial TRO, the extension motion 23 is granted. The TRO shall continue through 09/05/2023. The Plaintiff shall file a motion for preliminary injunction if appropriate by 09/01/2023. The tracking status hearing of 08/25/2023 is reset to 09/08/2023 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file a status report by 09/01/2023. Also, the Plaintiff shall promptly effectuate service of process as soon as the ex parte nature of the case expires. Mailed notice

MOTION by Plaintiff Crypton Future Media, Inc. for preliminary injunction (Quezada Hastings, Sofia)

MEMORANDUM by Crypton Future Media, Inc. in support of motion for preliminary injunction 26

(Declaration of Sofia Quezada Hastings)(Quezada Hastings, Sofia)

STATUS Report by Crypton Future Media, Inc. (Quezada Hastings, Sofia)

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

SUMMONS Returned Executed by Crypton Future Media, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 8/31/2023, answer due 9/21/2023. (Quezada Hastings, Sofia)

MINUTE entry before the Honorable Edmond E. Chang: In light of the same circumstances that justified entry of the initial TRO, the motion for preliminary injunction 26 is granted. The sealed filings shall be unsealed. The Plaintiff shall promptly effectuate service and file the proof of service when accomplished. The tracking status hearing of 09/08/2023 is reset to 10/20/2023 at 8:30 a.m., but to track the case only (no appearance is required, the case will not be called). Instead, the parties shall file the joint initial status report by 10/12/2023 (or the Plaintiff shall file it if the Defendants have not appeared). Emailed notice

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Edmond E. Chang on 09/07/2023. Emailed notice

NOTICE of Voluntary Dismissal by Crypton Future Media, Inc. of All Defendants (Quezada Hastings, Sofia)

MINUTE entry before the Honorable Edmond E. Chang: Pursuant to the notice of voluntary dismissal 32, under Federal Rule of Civil Procedure 41(a)(1)(A)(i), the case is dismissed with prejudice with each party to bear its own costs and fees. Status hearing set for 10/20/2023 is vacated. Civil case terminated. Emailed notice

MOTION by Plaintiff Crypton Future Media, Inc. for Return of Bond (Quezada Hastings, Sofia)

ORDER Signed by the Honorable Edmond E. Chang on 10/30/2023: Given that the case has reached judgment, the Plaintiff's motion for return of bond 34 is granted. The Clerk's Office shall return the bond. Emailed notice

MINUTE entry before the Honorable Edmond E. Chang: The Court having granted Plaintiff's motion for return of bond, R.35, the Clerk of Court shall release the $1,000 bond posted by Plaintiff and directs the Clerk of the Court to return the $1,000 bond previously deposited with the Clerk of the Court to plaintiff's counsel Aronberg Goldgehn Davis & Garmisa IOLTA Account, 225 West Washington Street, Suite 2800 Chicago, IL 60606, plus any accrued interest, minus the register fee, if any. Emailed notice

EMAILED copy of order [36] to U.S. District Court Fiscal Department.

EMAILED copy of order 36 to U.S. District Court Fiscal Department.