2023-cv-15688

COMPLAINT filed by EnchantedMob, Inc., Mob Entertainment, Inc.; Filing fee $ 402, receipt number AILNDC-21301379.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Schedule A regarding complaint[1]

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by EnchantedMob, Inc., Mob Entertainment, Inc.

Notice of Claims involving Trademarks by EnchantedMob, Inc., Mob Entertainment, Inc.

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Kahlia Roe Halpern

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Keri L Holleb Hotaling. Case assignment: Random assignment. (Civil Category 2). (mek,)

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,)

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Quinn Bradley Guillermo

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for temporary restraining order 11

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Zach Belanger regarding memorandum in support of motion 12

Exhibit 1

Exhibit 2

(Exhibit 3)

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Exhibit 4 - Parts 1-6 regarding declaration 14

Exhibit 4-1

Exhibit 4-2

Exhibit 4-3

Exhibit 4-4

Exhibit 4-5

(Exhibit 4-6)

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for miscellaneous relief 16

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 17

Exhibit 1

(Exhibit 2)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for leave to file 3, motion for miscellaneous relief 16, motion for temporary restraining order 11 before Honorable Manish S. Shah on 11/14/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions [3] [11] [16] 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 11/13/2023. Notices mailed.

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

SURETY BOND in the amount of $ 50,000 posted by EnchantedMob, Inc., Mob Entertainment, Inc. (Document not scanned.)

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for extension of time of Temporary Restraining Order

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of extension of time 22

(Declaration of Kahlia R. Halpern)

NOTICE of Motion by Kahlia Roe Halpern for presentment of extension of time 22 before Honorable Manish S. Shah on 11/22/2023 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 22 is granted, and no appearance is necessary. The TRO is extended to 12/11/23. Notices mailed.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendants

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for preliminary injunction as to Certain Defendants

Exhibit A

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for preliminary injunction[28]

Declaration of Kahlia R. Halpern

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction[28] before Honorable Manish S. Shah on 12/7/2023 at 09:45 AM.

Exhibit A

SUMMONS Returned Executed by EnchantedMob, Inc., Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/4/2023, answer due 12/25/2023.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: No appearance on 12/7/23 is necessary. Any objections to the motion for a preliminary injunction must be properly filed by 12/6/23 at 5pm U.S. Central Time. If no objections are filed, the motion will be considered unopposed. Notices mailed.

CERTIFICATE of Service by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. regarding terminate hearings, [32]

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: No objections to the motion for a preliminary injunction were filed by the deadline set by the court. The motion [30] is unopposed and granted. For the same reasons the TRO issued, the court finds that a preliminary injunction is appropriate. 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 12/7/2023. Notices mailed.

NEW PARTIES: Suzhou Xinjiayuan Home Textile Co., Ltd., Yiwu City Lvcheng E-Commerce Firm, Yiwu L&Y Import & Export Co., Ltd., Anime World Toy Store, Baboon Educational Toy Store Store, Shop726174 Store, TOMY COLLECTION Store, Upetstory Workshop Store, Y D Store, A13KYJ89AVXPC4, A38Z8TTVX0X90V, AHAKAC Deals Store, AUMEUMLGGLBZW, BinZhouPANYAN, BULUOGEDI, daiziyi-us, guangzhoulikaishangmaoyouxiangongsi779, HAII DUON SHOP, HOANG LE VY GS SHOP, IBTZAD-us, jianglanlan888, jinanguangzhenxinxiji, JIUBAN-MG, JJHXMAOYI, jrtjejewjjrj, juxianlaijing, Lucky House888, LXWBMDM, MinZhiYin, NIKIFAA, Qiduring, rizhaocaihui, rizhaofengjie, rizhaohanchui, songxyun1980, stones trust shop, SUNDI-US, Suveng, tianhuiweidedianpu, WEQXFVG, xiamenshixianganqulixiongxiongzhongzhi, XIAO SHU, XiYTongr, YEejyog, yuhongweiymx, yunxiaoxianhongxiubaihuodian, yunxiaoxianjipanbaihuodian, yunxiaoxianleifanbaihuodian, yunxiaoxianmuyibaihuodian, yunxiaoxianxinyaobaihuodian, yunxiaoxianzhengsibaihuodian, zemeibaihuodian, ZHANGSHILONG380, zhuyuechuanmei, smyy3, tewry, twzpk, uahb, uvds, vnrc, xing08, youngstore07, z6nf, menga101, starlightintelligent0, aw6_79, AKKO Anime Doll, BAOEN, BFLAAE, Childlike moments, Focus on crossborder toy, HONEY BABY KIDS, Jiaqin toy factory, MANSI, Miss Luo Shop, Niyofa Toys, OLchee Small toys, RCHRKUS, SiLiang, Sweety Life, Watty, YANGCY, PUTIAN, Fangqinghaofa, HAOYUDECANG and Orange Sunrise added to case caption.

SUMMONS Returned Executed by Mob Entertainment, Inc., EnchantedMob, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 12/11/2023, answer due 1/1/2024.

Declaration of Quinn B. Guillermo

Exhibit A

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

NOTICE of Voluntary Dismissal by All Plaintiffs 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.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to a Certain Defendant

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for entry of default, MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. in support of motion for entry of default, motion for default judgment, [41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[42]

Exhibit 1

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default, motion for default judgment, [41] before Honorable Manish S. Shah on 1/9/2024 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. The motion for entry of default judgment [41] is granted. Enter Default Judgment Order. Terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 1/9/2024. Notices mailed.

FULL SATISFACTION of Judgment regarding order 46 as to certain defendant

FULL SATISFACTION of Judgment regarding order 46 as to certain defendant

FULL SATISFACTION of Judgment regarding order 46 as to certain defendant

NOTICE of withdrawal of Surety bond 25 by John Summerfield. (Received at the Intake Counter on 03/29/24) (Received for docketing 04/05/24)

FULL SATISFACTION of Judgment regarding order 46 in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] in the amount of $50,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order[46] in the amount of $50,000 as to certain defendant