2023-cv-05182

COMPLAINT filed by Svenja Schmitt; Filing fee $ 402, receipt number AILNDC-20903467.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Svenja Schmitt Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Yanling Jiang

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Yi Bu

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Adam Grodman

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Svenja Schmitt by Monica Rita Martin

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Beth W. Jantz. 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 DOCUMENT by Plaintiff Svenja Schmitt [CORRECTED] Schedule A to Complaint 1 and Schedule A to Complaint 2

MOTION by Plaintiff Svenja Schmitt for leave to file under seal

MOTION by Plaintiff Svenja Schmitt for leave to file excess pages

MEMORANDUM in support of 13 Exparte motion

Declaration of Keith A. Vogt

Exhibit 1-4, of Keith A. Vogt's declaration

Declaration of Svenja Schmitt

(Exhibit 1, of Svenja Schmitt's declaration)

SEALED EXHIBIT by Plaintiff Svenja Schmitt Sealed Exhibit 2, Declaration of Svenja Schmitt regarding memorandum in support of motion, 14

Exhibit 2-1

Exhibit 2-2

(Exhibit 2-3)

Presentment for Exparte motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 11, motion for leave to file excess pages 12 before Honorable Manish S. Shah on 8/15/2023 at 09:45 AM.

MAILED Copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Manish S. Shah: No appearance on 8/15/23 for the ex parte motions is necessary. The court requests that plaintiff file a supplemental sealed exhibit listing each defendant and the corresponding copyright registration number for an allegedly infringing work (with citation to page number from the ECF header in the filed screen shots). In the court's initial review, for example, the court did not see a work allegedly infringing VA 2-341-843 (but maybe it missed it in the hundreds of pages of exhibits). Plaintiff must tailor the requested injunctive relief to only the works for which it has evidence of infringement. The ex parte motions are under advisement.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's supplemental sealed exhibit, see 18, is due by 8/31/23. Notices mailed.

SEALED EXHIBIT by Plaintiff Svenja Schmitt Supplemental Sealed Exhibit Chart regarding terminate hearings, text entry, 18, text entry 19

(Supplement Sealed Exhibit Chart)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion for a temporary restraining order, asset restraint, expedited discovery, and electronic service of process, motion for excess pages, and motion to seal 11 12 13 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 as to the defendants listed in Schedule A and the 8 copyrighted works identified in the supplemental exhibit 20, 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 $100,000 bond is sufficient to secure the injunction for over 200 defendants. Enter Sealed TRO. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 9/5/2023. Notices mailed.

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

SURETY BOND in the amount of $ 100,000 posted by Svenja Schmitt. (Document not imaged)

MOTION by Plaintiff Svenja Schmitt for preliminary injunction

MEMORANDUM by Svenja Schmitt in support of motion for preliminary injunction 24

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 24 before Honorable Manish S. Shah on 9/19/2023 at 09:45 AM.

SUMMONS Returned Executed by Svenja Schmitt as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/13/2023, answer due 10/4/2023.

(Declaration of Service)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for preliminary injunction 24 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 9/19/2023. Notices mailed.

NEW PARTIES: wanzaixianpengningtibaihuodian, chengdukuaishenshoudianzishangwuyouxiangongsi9, DDEET, Qacweer, NJNT, sscrrtyer, Islained339, sweet years, Lufei USA, Pingpi, ColorTubes, GONGGU Store, XINAGXI US, 365LIVEYG, koopder, NICELYG, Rice Tomorrow, zhZh%h, DIHOMI, Luckybunny, Yzrwebo, qujingwangleidianzishangwuyouxiangongsi, A4 SG OMICRON PTE. LTD., Kevin Patience, yuanzhouquqinxinyubaihuodian, LGstart, Tay-US, Dsisskai, MAChiDEAOZHou, YSIBIT, ChangYuanShiYuJiaBaiHuoDian, BIYINGEE, THGO, seulife, MQBAIHUODIAN, LEHA, LFJart, SHGUORZ, hejinshijubinshangmaoyouxiangongsi, Strnek1, Wandisy, HappyGold, randeczh, YIGOLD, Komking, guirus and Pakky added to case caption.

NEW PARTIES: Fartunedo, MUMUBAIHUOJINGYINGDIAN, XIJXLK, JMbuild, Home textile bedding, Jy-seven, Rimedtsv, Bokze, CCDMJ, THANH THANH EMTM SHOP, AU VAN PHONG, haiboqihaiboqi, TTIKF, Dalicoter, kefityzo, huisiyubaihuoshangdian, Kevin zhangxiang, MINGXCRAFT, xiangchengshimengpingshineimendian, UIKYMOO, XUNQIKEJI, LHL STORE, suizhoushizengduquhaoquanyongshangmaozhongxin, LUFAHANG, MADE4U US, lingxiaohui, YangC Store, yuchongqin098, shanjingbaihuoyouxianzerengongsi, Hantong-Star, YQSMHF, putianshichengxiangqusiwusongxieyedian, Pink baby store, yuanxin-shop, Miguo shop, Pinone, Oottati, JenPsaon, xiuxian US, ESH7, Aitterl, UriahMall, EOWJEED, YAXIANG, SYAIMN, Meiyantou Co., Ltd, WZPB, Moresale, XIAOTANG, Ayzr, Tiehua Fashion Store, Theresa Bedding, DUONASHANGMAOYOUXIANGONGSI, QINGUANGSHANGNAO, XinHuaQuYuanLin, Xuchaoshangmao, LINBONIN, Umama Shop and Qudiyin-XD added to case caption.

NEW PARTIES: LAHL, FEASRT, Hana_Pita, CHENWU, Mirabelle ting, brightness, PETSBASE-US, youyuanrenjiankang, YingNan, Li Ying us, Wekijau, Lcefashion, DAHUHU, Yanmucy2020, hardharmonica, woodone, ZhangZhuJun, Jiaxuan grocery store, Cui Chenyang, BaiFeiEr, AiYouDimaoyi, Kifdiifgoso, Wang Binhao, maisenUS, departed soul, Shen Dingming, Liu Junhao, matxin, beamgeer, Anrini Factory, pedriet, YYZAZCY, LDshengfei, Jekeno, Exquisite Home textiles, CLASSIC HOME, XIANGGANGSHI, Tutustores, Sitadi, NINGNINGBAIHUO, Unicey, Josid, chenlingyan008, MeiRongSen, Happie Family, ManningUS, lulaprooits, SYSZUKJ and MUOOUM added to case caption.

NEW PARTIES: Rrainbowssun, Beginana, houquandongdianpu, pingdingshanshibilouxuanshangmaoyouxiangongsi, ANGGREK K-US, zjchao123, Aohicon-US, Sun Store USA, Autuoman, Luckydan, Suntaskw, yuytee, Huihsga001-US, Qinlorgoo, Yuze-US, VINGVO, zhanghui23, Jadpes mg, Zeoo, yafa, Huzruen, Taiddad, nusind, yiuo gui fu, Dgoopd US Favorite Clothes Store, Ozmmyan, charmsamx, DEYIOU Store, NoxwB, Bufgaceh, Erdkk, SERCFGYUJ, Sunaei, zupvkai, Naimuddin Seikh, LBJTAKDP, US Newest women's clothing(7-14 Days Delivery), DECEMBE12, PAALEI, YYDSKB, GreatGiftList and Charella Shop added to case caption.

NEW PARTIES: ' added to case caption.

NEW PARTIES: '' added to case caption.

NEW PARTIES: TienDat - sell added to case caption.

NEW PARTIES: BYOIMUD'Top Sweatshirts 7-14 days Business added to case caption.

NEW PARTIES: Haoawi **7-18 **Days Delivery added to case caption.

NEW PARTIES: Defendant no. 30, Defendant no. 83 and Defendant no. 205 added to case caption.

ATTORNEY Appearance for Defendants AiYouDimaoyi, BaiFeiEr, Cui Chenyang, Kifdiifgoso, Liu Junhao, Luckydan, Shen Dingming, Strnek1, Suntaskw, VINGVO, Wandisy, Wang Binhao, Yuze-US, Zeoo, zjchao123 by Timothy Tiewei Wang

(Exhibit A - List of Represented Defendants)

MOTION by Defendants AiYouDimaoyi, BaiFeiEr, Cui Chenyang, Kifdiifgoso, Liu Junhao, Luckydan, Shen Dingming, Strnek1, Suntaskw, VINGVO, Wandisy, Wang Binhao, Yuze-US, Zeoo, zjchao123 for extension of time to file answer regarding complaint 1

NOTICE of Motion by Timothy Tiewei Wang for presentment of motion for extension of time to file answer, 31 before Honorable Manish S. Shah on 10/10/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time to answer 31 is granted. Defendants AiYouDimaoyi, BaiFeiEr, Cui Chenyang, Kifdiifgoso, Liu Junhao, Luckydan, Shen Dingming, Strnek1, Suntaskw, VINGVO, Wandisy, Wang Binhao, Yuze-US, Zeoo, and zjchao123 have until 10/18/23 to respond to the complaint and if the parties have not settled, they must file a joint initial status report with a proposed case schedule by 10/23/23. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

MOTION by Plaintiff Svenja Schmitt for default judgment as to The Defendants Identified In First Amended Schedule A

MEMORANDUM by Svenja Schmitt in support of motion for default judgment 35

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 35 before Honorable Manish S. Shah on 10/17/2023 at 09:45 AM.

Re- NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 35 before Honorable Manish S. Shah on 10/19/2023 at 09:45 AM.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

NOTICE of Voluntary Dismissal by All Plaintiffs as to Defendant no. 18 zhZh%h

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motion for default judgment 35 is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT FINAL JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 10/19/2023. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to [Certain] defendants

SATISFACTION of Judgment as to Defendant no. 111 LAHL and no. 197 LBJTAKDP

SATISFACTION of Judgment as to Defendant no. 71 XUNQIKEJI

SATISFACTION of Judgment as to Defendant no. 93 UriahMall

SATISFACTION of Judgment as to Defendant no. 58 Bokze