2023-cv-14326

COMPLAINT filed by Epic Games, Inc.; Filing fee $ 402, receipt number AILNDC-21167095.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

SEALED EXHIBIT by Plaintiff Epic Games, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiff Epic Games, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Epic Games, Inc.

Notice of Claims Involving Trademarks by Epic Games, Inc.

ATTORNEY Appearance for Plaintiff Epic Games, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiff Epic Games, Inc. by Sydney Paige Fenton

CASE ASSIGNED to the Honorable Robert W. Gettleman. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2).

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 Epic Games, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Epic Games, Inc. in support of motion for miscellaneous relief[9]

Declaration of Martin F. Trainor

Exhibit 1

DECLARATION of Paul Varley regarding memorandum in support of motion[10]

Exhibit 1

SEALED EXHIBIT by Plaintiff Epic Games, Inc. Exhibit 2, Parts 1-8 regarding declaration[11]

Exhibit Exhibit 2, Part 1

Exhibit Exhibit 2, Part 2

Exhibit Exhibit 2, Part 3

Exhibit Exhibit 2, Part 4

Exhibit Exhibit 2, Part 5

Exhibit Exhibit 2, Part 6

Exhibit Exhibit 2, Part 7

(Exhibit Exhibit 2, Part 8)

MOTION by Plaintiff Epic Games, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Epic Games, Inc. in support of motion for miscellaneous relief[13]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Motion for Leave to File Certain Documents Under Seal [3], Motion for Electronic Service of Process Pursuant to Fed. R. CIV. P. 4(f)(3) [13] and Ex Parte Motion for Entry of a Temporary Restraining Order, Including A Temporary Injunction, A Temporary Asset Restraint, And Expedited Discovery [6] are granted. Enter sealed order. Telephonic hearing set for 10/25/2023 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

SEALED TEMPORARY Restraining Order signed by the Honorable Robert W. Gettleman on 10/11/2023. Mailed notice

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

CIVIL BOND in the amount of $ 10,000 posted by Epic Games, Inc.

MOTION by Plaintiff Epic Games, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Epic Games, Inc. in support of motion for miscellaneous relief[18]

Declaration of Martin F. Trainor

MINUTE entry before the Honorable Robert W. Gettleman: Plaintiff's Ex Parte Motion To Extend The Temporary Restraining Order [19] is granted. Enter order. Telephonic hearing set for 10/25/2023 is stricken and rest to 11/7/2023 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

EXTENSION OF TEMPORARY RESTRAINING ORDER signed by the Honorable Robert W. Gettleman on 10/20/2023. Mailed notice

SUMMONS Returned Executed by Epic Games, Inc. as to The Partnerships and Unincorporated Associations Identified On Schedule A on 11/2/2023, answer due 11/23/2023.

Declaration of Sydney Fenton

Exhibit A

MOTION by Plaintiff Epic Games, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Epic Games, Inc. in support of motion for preliminary injunction[23]

Declaration of Martin F. Trainor

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for preliminary injunction[23] before Honorable Robert W. Gettleman on 11/7/2023 at 09:15 AM.

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 11/7/2023. No defendant appeared on the hearing. For the reasons stated on the record Plaintiff's Motion For Entry Of A Preliminary Injunction [23] is granted. Enter order. The law firm of TME Law, P.C. is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website located at www.ilnd.uscourts.gov/instructions. The Clerk is directed to unseal Schedule A to the Complaint [2], Exhibit 2 to the Declaration of Paul Varley [12], and the TRO [16]. Telephonic hearing set for 12/20/2023 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Robert W. Gettleman on 11/7/2023. Mailed notice

NEW PARTIES: Guangzhou Junmeng Trading Co., Ltd., Quanzhou Best Supply Chain Management Co., Ltd., Carebaby Store, Child Boy T-shirt Hoodie Store and GUBEI TOYS Store added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A

NEW PARTIES: Hasbro Marvel Legends toy Store, heylisten Store, Marvel Comics Collection Model Toy shop Store, O2O Wholesale Toy Store Store, QiuQiu Party Store, RZ-STORE Store, Shop1100024058 Store, Shop1100352273 Store, Shop2944135 Store, Shop910561133 Store, Shop912643093 Store, smilewill 01 Store, Star Road Store, Suman model Store, Zhuoxian Children Clothes Store, fh4j, foo_jiao, fzctl2, gcdscloth, genben1024, gewuxuan, gleestorey, gucci558, adzj, ahj1, aizi01, akingongs, albbclothing, amzj and animetravel added to case caption.

NEW PARTIES: ascs_sneakers, asgo, bestpricewall, bestshop02, bkpl, bossjunsa, buyannadhty, buygoodbelts, buygoodroom, buyluckygood, carters1, clothes_shop8, clothes688s, clothestore01, clothesvlon, clothkkxx, clothniux, cnccclothes, cninga, cningb, coat01, csgoclothing, cui1dhgates, cycinternational, dalula Store, Das883, db7g, designer2022, designerdior, dhclothing881, dhfashionmerchs, dhgatelz, dhgatety and dhgatexy added to case caption.

NEW PARTIES: dhgatop, dhhrtubuy, dhstreetwears, dior688, djyg, dress6688, elnl, enjoy_factory, evisu_designer01, facaizyh2, fali2, fans_jersey_mall, fed26, health_lifes, hoodies66, hxx1224, iism, ikfushi, ioctopus, jdee, jeans3, jiabuydhiu, jinai001, jinkouaodi, jishencifu, jitc, jizc, jjhp, justbuyits and langquancos added to case caption.

NEW PARTIES: lianwu07, looyuses, luckypans, luckysdhgate, lv899, lxysq, lyouyip0, make07, maosgetian, mature_, meisaidesitrade, mensstore01, minclothes, morr, mrc888, newtodaynew, newyeargan, nokg, noteo, nrd5, nsc7, o7zw, ocf8, pchengfugood, phkfuzecheng03, ponestopwholesale, pwhk, pyihai2021, rerh, s29x, saringbaodian, sexycthing, sh2y, sihuai01, supreme99, tee0101, tee0303, tee0606 and tee0909 added to case caption.

NEW PARTIES: Top brand Store, top12, tphk, tracksuits001, tshirt99, voay, volkswagenclothing, wg7900, wizb, wmpr, wuling50, wuxh110_clo, yanyanzi001, yuekaiele, yuexiandengs, yzz122, zbzt, zubv, zy00001, Jinjiang Chaote Co., Ltd, Su Zhou Offer Gifts Co., Ltd., YC Clothing Co., Ltd., dhgateandycool, Art Design Gallery Store and D-I-Y diamonds paintings Store added to case caption.

MAILED trademark report to Patent Trademark Office, Alexandria VA.

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

NOTICE of Voluntary Dismissal by Epic Games, Inc. as to a certain defendant

NOTICE of Voluntary Dismissal by Epic Games, Inc. as to certain Defendants

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 12/20/2023. No defendants appeared on the hearing. Plaintiff reported it is continuing negotiations with various defendants and will file a motion for default against those that have not appeared. Telephonic hearing set for 1/25/2024 at 9:15 a.m. on the Webex platform. Parties will not be asked to start their video. Counsel of record and other essential case participants will receive an email prior to the start of the hearing with instructions to join the hearing. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

NOTICE of Voluntary Dismissal by Epic Games, Inc. as to certain Defendants

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.

ATTORNEY Appearance for Plaintiff Epic Games, Inc. by Alexander Whang

MOTION by Plaintiff Epic Games, Inc. for entry of default, MOTION by Plaintiff Epic Games, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Epic Games, Inc. in support of motion for entry of default, motion for default judgment[36]

Exhibit 1

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[37]

Exhibit 1

NOTICE of Motion by Martin Francis Trainor for presentment of motion for entry of default, motion for default judgment[36] before Honorable Robert W. Gettleman on 1/25/2024 at 09:15 AM.

ATTORNEY Appearance for Plaintiff Epic Games, Inc. by Richard M. Poskozim

MINUTE entry before the Honorable Robert W. Gettleman: Telephonic hearing held on 1/25/2024. No defendant appeared on the hearing. For the reasons stated on the record, Plaintiff's Motion For Entry Of Default And Default Judgment [36] is granted. Enter Final Judgment. Civil case terminated. Mailed notice

FINAL JUDGMENT ORDER signed by the Honorable Robert W. Gettleman on 1/25/2024. Mailed notice

FULL SATISFACTION of Judgment as to a certain defendant