2023-cv-07249

COMPLAINT filed by Jumali Bin Katani; Filing fee $ 402, receipt number AILNDC-21013048.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Jumali Bin Katani Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Yanling Jiang

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Yi Bu

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Adam Grodman

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiff Jumali Bin Katani by Monica Rita Martin

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Heather K. McShain. 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 Jumali Bin Katani for leave to file under seal

MOTION by Plaintiff Jumali Bin Katani for leave to file excess pages

MEMORANDUM in support of 12 Exparte motion

Declaration of Keith A. Vogt

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

Declaration of Jumali Bin Katani

(Exhibit 1, of Jumali Bin Katani)

SEALED EXHIBIT by Plaintiff Jumali Bin Katani Sealed Exhibit 2, Declaration of Jumali Bin Katani. regarding memorandum in support of motion, 13

Exhibit 2-1

(Exhibit 2-2)

Presentment for Exparte motion 12 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 11, motion for leave to file 10 before Honorable Edmond E. Chang on 9/13/2023 at 08:30 AM.

MOTION by Plaintiff Jumali Bin Katani for leave to file under seal

MOTION by Plaintiff Jumali Bin Katani for leave to file excess pages

MINUTE entry before the Honorable Edmond E. Chang: In this copyright-infringement case, the Plaintiff's motion 19 for temporary restraining order and other relief is granted. (The prior motion 12 is terminated as superseded.) 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 17 U.S.C. § 504(b), which is not a mere common-law equitable claim and thus could allow for pre-judgment restraint. Indeed, copyright owners need only prove "the infringer's gross revenue"; the defendant must prove expenses. 17 U.S.C. §504(b). To the extent that the restraint might be too broad, the Defendant 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 17 for leave to file under seal is granted in light of the asset-restraint goal. (The prior motion 10 to seal is terminated as superseded.) A redacted version of the TRO will be entered publicly (redacting the name of Defendant and omitting Amended Schedule A). The Plaintiff's motion 18 for extra pages is granted. (The prior motion 11 is terminated as superseded.) To track the case only (no appearance is required, the case will not be called), a status hearing is set for 09/29/2023 at 8:30 a.m. The Plaintiff shall file the TRO extension motion (or a preliminary injunction motion) no later than 09/22/2023. Emailed notice

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Edmond E. Chang on 09/12/2023. Emailed notice

(PUBLIC VERSION) SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Edmond E. Chang on 09/12/2023. Emailed notice

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

SURETY BOND in the amount of $ 10,000 posted by Jumali Bin Katani. (Document not Scanned)

MOTION by Plaintiff Jumali Bin Katani for preliminary injunction

MEMORANDUM by Jumali Bin Katani in support of motion for preliminary injunction 27

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 27 before Honorable Edmond E. Chang on 9/26/2023 at 08:30 AM.

SUMMONS Returned Executed by Jumali Bin Katani as to The Partnerships and Unincorporated Associations Identified on Schedule A on 9/14/2023, answer due 10/5/2023.

(Declaration of Service)

MINUTE entry before the Honorable Edmond E. Chang: In light of the circumstances that justified entry of the TRO, the Plaintiff's motion 27 for preliminary injunction is granted. Given the answer deadline of 10/05/2023, the tracking status hearing of 09/29/2023 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 10/13/2023. But if the Defendant does not answer on time, then the Defendant shall be deemed in default and the Plaintiff shall file the default-judgment motion on 10/13/2023 instead. Mailed notice

PRELIMINARY Injunction Order Signed by the Honorable Edmond E. Chang on 9/25/2023. Mailed notice

NEW PARTIES: KIJBLAE added to case caption.

MOTION by Plaintiff Jumali Bin Katani for default judgment as to The Defendants Identified In [Amended] Schedule A

MEMORANDUM by Jumali Bin Katani in support of motion for default judgment 34

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

MINUTE entry before the Honorable Edmond E. Chang: On review of the Plaintiff's motion for default judgment 34, the motion is granted. As explained in the Order, the fifteen-thousand dollars ($15,000) statutory damages award is appropriate. In light of the willfulness established by the default, the permanent injunction is granted. A separate AO-450 judgment shall be entered. The tracking status hearing of 10/20/2023 is vacated. Civil case terminated. Emailed notice

DEFAULT FINAL JUDGMENT ORDER Signed by the Honorable Edmond E. Chang on 10/13/2023. Emailed notice

ENTERED JUDGMENT Signed by the courtroom deputy on 10/13/2023. Emailed notice

SATISFACTION of Judgment as to defendant no. 1 KIJBLAE