2023-cv-13941

COMPLAINT filed by BBC Studios Distribution Ltd; Filing fee $ 402, receipt number AILNDC-21117319.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Schedule A regarding complaint[1]

MOTION by Plaintiff BBC Studios Distribution Ltd for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BBC Studios Distribution Ltd

Notice of Claims Involving Trademarks by BBC Studios Distribution Ltd

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Rachel S Miller

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Trevor Christian Talhami

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Quinn Bradley Guillermo

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. (Text entry; no document attached.)

MOTION by Plaintiff BBC Studios Distribution Ltd for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for temporary restraining order 12

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 13

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Diane Hamer regarding memorandum in support of motion 13

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Exhibit 3 Parts 1-7 regarding declaration 15

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

(Exhibit 3-7)

MOTION by Plaintiff BBC Studios Distribution Ltd for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for miscellaneous relief 17

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 18

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 17, motion for temporary restraining order 12 before Honorable Manish S. Shah on 9/27/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, asset restraint, and expedited discovery, and motion for electronic service of process [3] [12] [17] are granted, and no appearance on the motions is necessary. 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, 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 $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 9/26/2023. Notices mailed.

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Trevor Christian Talhami

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A (Text entry; no document attached.)

SURETY BOND in the amount of $50,000 posted by BBC Studios Distribution Ltd (Document not scanned.)

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order

MEMORANDUM by BBC Studios Distribution Ltd in support of extension of time 25

(Declaration of Rachel S. Miller)

NOTICE of Motion by Rachel S Miller for presentment of extension of time 25 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 25 is granted, and no appearance on 10/10/23 is necessary. The TRO is extended to 10/24/23. Notices mailed.

MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for preliminary injunction[29]

Declaration of Rachel S. Miller

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for preliminary injunction[29] before Honorable Manish S. Shah on 10/24/2023 at 09:45 AM.

Exhibit A

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to Certain Defendants

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/19/2023, answer due 11/9/2023.

Declaration of Trevor C. Talhami

Exhibit A

ATTORNEY Appearance for Defendant Bad bad girl by Yong Chen

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to Certain Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [29] 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 10/24/2023. Notices mailed.

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NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendant

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/26/2023, answer due 11/16/2023.

Declaration of Trevor C. Talhami

(Exhibit A)

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendant

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to Certain Defendants

MOTION by Plaintiff BBC Studios Distribution Ltd for entry of default, MOTION by Plaintiff BBC Studios Distribution Ltd for default judgment as to all Defendants

Exhibit A

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for entry of default, motion for default judgment[45]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[46]

Exhibit 1

NOTICE of Motion by Rachel S Miller for presentment of motion for entry of default, motion for default judgment[45] before Honorable Manish S. Shah on 12/5/2023 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Judge Shah is not hearing motions on 12/5/23. Plaintiff's motion for entry of default judgment 45 is reset to 12/6/23 at 9:45 a.m. Notices mailed.

ATTORNEY Appearance for Defendants ZSENA, longdashiye by Adam Edward Urbanczyk

MOTION by Defendants ZSENA, longdashiye for extension of time

ATTORNEY Appearance for Defendants ZSENA, longdashiye by Brian Swift

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to Certain Defendants

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motion for extension of time [51] is granted. Defendants ZSENA and longdashiye must respond to the complaint by 12/26/23. For the reasons stated in open court, the motion for entry default judgment [45] is granted as to the remaining defendants. Enter default judgment order. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/6/2023. Notices mailed.

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 BBC Studios Distribution Ltd as to certain defendants

FULL SATISFACTION of Judgment regarding order[55] as to certain defendant

MINUTE entry before the Honorable Manish S. Shah: All of plaintiff's claims having been resolved, this case is dismissed. Civil case terminated. Notices mailed.

FULL SATISFACTION of Judgment regarding order[55] as to certain defendant

FULL SATISFACTION of Judgment regarding order 55 as to certain defendant