2023-cv-14050

COMPLAINT filed by Khara Inc., Ground Works Co., Ltd.; Filing fee $ 402, receipt number AILNDC-21137846.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Keith A. Vogt

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yanling Jiang

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Yi Bu

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Adam Grodman

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Cameron Eugene Mcintyre

ATTORNEY Appearance for Plaintiffs Ground Works Co., Ltd., Khara Inc. by Monica Rita Martin

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Ground Works Co., Ltd., Khara Inc.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Jeffrey Cummings. 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. (mek,)

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for leave to file under seal

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. 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 Yasuhiro Kamimura

(Exhibit 1, of Yasuhiro Kamimura's declaration)

SEALED EXHIBIT by Plaintiffs Ground Works Co., Ltd., Khara Inc. Sealed Exhibit 2, Declaration of Yasuhiro Kamimura regarding memorandum in support of motion, 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

Exhibit 2-4

(Exhibit 2-5)

Presentment for Exparte motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 12, motion for leave to file 11 before Honorable Elaine E. Bucklo on 10/4/2023 at 09:45 AM.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

(Trademarks)

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

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for leave to file under seal [11] ; Plaintiff's motion to exceed page limitation [12]; and Plaintiffs' Ex Parte motion for entry of temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery and service of process by email and/or electronic publication [13] are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 10/18/2023, any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 10/11/2023. Keith Vogt, Ltd. is ordered to add all defendant names listed in the Schedule A to the docket within three business days of the expiration of the TRO. Instructions can be found on the court's website located at https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. The case is set for a status hearing on 11/20/2023 at 9:45 a.m. (to track the case only, no appearance is required). By 11/13/2023 plaintiff is to file a status report regarding the status of service of process, settlement discussions, and any further information that plaintiff wishes to bring to the Court's attention. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER signed by the Honorable Elaine E. Bucklo on 10/4/2023. Mailed 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 Ground Works Co., Ltd., Khara Inc. (Document not scanned.)

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for preliminary injunction

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for preliminary injunction 22

Declaration of Keith A. Vogt

(Exhibit 1, Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 22 before Honorable Elaine E. Bucklo on 10/18/2023 at 09:45 AM.

NEW PARTIES: 8s7126, agli_12, alanliujin, an85479, arlg93, autoueendel, b6yo6dg, bahru_20, binrbn87, bizhi-60, cezho_12, chengdujinzhuzeng-0, chengdutulunpuzhanshishebeiyouxiangongsi, chinarvasuk_0, coxt1479, cvtt_71, decan-29, delil57, egvi-49, fasap21, fengk_47, fjbs_366, fn29_19, gaotef-9257, gfdc-88, ghbf-844, gpx078318393, guangbin lu, gy16_82, hairong_2855, hicare, hong36, houxueren, huihui86_7, i6po25, i9s3_21, irjz010822844-0, iuxi-37, jiangkai, kei8338, keu_64, key7_44, kimberlgriffit88, litchi521, liu0-d2ncz2, lmhuvfde-0, longren505, ltbtbanba8899, luckinsm11 and meizhongbuzu added to case caption.

NEW PARTIES: mercha2105, mhhh44, monalmahaja_0, nach-3048, nafit-4, niutiesha, pandacaf_0, piao25-13, pokus-58, pxd942, quicksell_co, rejat5229, rengdin_26, rifs-73, romambl93, rounanchen, sahabi_80, sharadha_store, smartside01, sodekukauya-3, sop3_3954, sunflower89, suykail_0, t3f_14, taidang_42, tammydenise1975, taochen08, toyland-85, uchunhel, vmc89-34, vu9635, xudengyue, yangbinbin, ybq284658, yunlen_4, zealotsin, zengk51, Zhenxiang Toy, zhihongearth0, zhutiesha, zirifumv, AndrewVeder, Bingons, BOUMSTEIN JONATHAN NATHANIEL, changzhishijiarongchenshangmaoyouxiangongsi, Chengdu Weiyong, chenjunjiehaibao, chuizidzmy, DaFu store, diranshangmao, DUCHUY96, Family Gift, fengll neon sign, Foshan Maishunfei Trading Co., Ltd., foshanshinanhaiqulingyuanshangmaoyouxiangongsi, GRR- Touch, guipi18, GXDP, Haral 1976 and hengyangshijiangyiwangluokejiyouxiangongsi added to case caption.

NEW PARTIES: Hong Lei Art, HONHUY GOODS, HTXShop, HUUDAT STORES, huweixiao, Jhumgalbek, JIAHUANG, jusaichao123, Kumquat, Kun Kun Shop, LaiDianZhenJiChangYanJiuShangHang, LEEVINHOME, Li Li Shop, matenglufei, Mr. Ninja, MVDBNFNBMK, MY HOME HAPPY, Nguyenquan, Phuong Hai, PINTUHEGUISTORE, putianshichengxiangquxuhuayimaoyiyouxiangongsi, RODRIGUEZTEE, shanxidiyiweiwangluokejiyouxiangongsi, sizon92mna, TiToNaTa, xiamenhongyujidiangongchengyouxiangongsi, xiapuxianpinhengfuzhuangjingyingbu, Youbo Department Store Business Department in Qinhuai District, Yutan Trading and zhangjingchun added to case caption.

NEW PARTIES: Defendant no. 141, Defendant no. 142, Defendant no. 143 and Defendant no. 144 added to case caption.

SUMMONS Returned Executed by Khara Inc., Ground Works Co., Ltd. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 10/13/2023, answer due 11/3/2023.

(Declaration of Service)

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's motion for entry of a preliminary injunction 22 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following documents: Plaintiffs' Schedule A to the Complaint 2, Exhibit 2 to the Declaration of Yasuhiro Kamimura 15, and the TRO 20. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 10/16/2023. Mailed notice.

MOTION by Plaintiffs Ground Works Co., Ltd., Khara Inc. for default judgment as to The Defendants Identified In First Amended Schedule A

MEMORANDUM by Ground Works Co., Ltd., Khara Inc. in support of motion for default judgment 28

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 28 before Honorable Elaine E. Bucklo on 11/20/2023 at 09:45 AM.

STATUS Report by Ground Works Co., Ltd., Khara Inc.

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

NOTICE of Voluntary Dismissal by All Plaintiffs as to defendant no. 86 zealotsin

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiffs' motion for entry of default and default judgment against the defendants identified in First Amended Schedule A 28 is granted. Enter Default Final Judgment Order. The Clerk of the Court is directed to return the surety bond posted in the amount of ten thousand dollar ($10,000) to GWC or its counsel, Keith Vogt, Ltd., 33 West Jackson Boulevard, #2W Chicago, Illinois 60604. Civil case terminated. Mailed notice.

DEFAULT FINAL JUDGMENT ORDER signed by the Honorable Elaine E. Bucklo on 11/20/2023. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs =as to defendant no. 44 htchi521