2023-cv-16654

COMPLAINT filed by Sega Corporation, Sega of America, Inc.; Filing fee $ 405, receipt number AILNDC-21410923.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

(Exhibit 5)

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Schedule A regarding complaint 1

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Leave to File Certain Documents Under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sega Corporation, Sega of America, Inc.

Notice of Claims Involving Trademarks by Sega Corporation, Sega of America, Inc.

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Martin Francis Trainor

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Sydney Paige Fenton

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Richard M. Poskozim

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Jeffrey Cole. Case assignment: Random assignment. (Civil Category 2). (Text entry; no document attached.)

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 Plaintiffs Sega Corporation, Sega of America, Inc. for Entry of a Temporary Restraining Order, Including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 10

Declaration of Martin F. Trainor

(Exhibit 1)

DECLARATION of Paul Varley regarding memorandum in support of motion 11

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Exhibit 3, Parts 1-18 regarding declaration 12

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

Exhibit 3-4

Exhibit 3-5

Exhibit 3-6

Exhibit 3-7

Exhibit 3-8

Exhibit 3-9

Exhibit 3-10

Exhibit 3-11

Exhibit 3-12

Exhibit 3-13

Exhibit 3-14

Exhibit 3-15

Exhibit 3-16

Exhibit 3-17

(Exhibit 3-18)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 14

Declaration of Martin F. Trainor

(Exhibit 1)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, and expedited discovery 10 is granted. Plaintiff's motion to seal 3 and motion for electronic service of process 14 are granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 12/21/2023. Mailed notice.

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Amended Schedule A to the Complaint regarding complaint 1

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to amend/correct SEALED Order 17

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' ex parte motion to amend the temporary restraining order 19 is granted. Enter Sealed Temporary Restraining Order. Mailed notice.

SEALED TEMPORARY RESTRAINING ORDER Signed by the Honorable Mary M. Rowland on 12/27/2023. Mailed notice.

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.

SURETY BOND in the amount of $ 198,000 posted by Sega Corporation, Sega of America, Inc. (Document not Scanned)

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to Extend the Temporary Restraining Order

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for miscellaneous relief 24

(Declaration of Martin F. Trainor)

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's ex parte motion to extend the temporary restraining order 24 is granted. TRO is extended to 1/24/24. Mailed notice.

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain Defendants

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

ATTORNEY Appearance for Plaintiffs Sega Corporation, Sega of America, Inc. by Alexander Whang

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. to amend/correct exhibit[2] Schedule A instanter

SEALED EXHIBIT by Plaintiffs Sega Corporation, Sega of America, Inc. Amended Schedule A regarding complaint[1]

SUMMONS Returned Executed by Sega Corporation, Sega of America, Inc. as to The Partnerships and Unincorporated Associations Identified On Schedule A on 1/19/2024, answer due 2/9/2024.

Declaration of Richard Poskozim

Exhibit A

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for preliminary injunction

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for preliminary injunction[33]

Declaration of Martin F. Trainor

Exhibit 1

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's motion for leave to file amended schedule a to the complaint under seal instanter [30] is granted. Mailed notice.

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion for entry of a preliminary injunction [33] is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff 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 https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_cmecf/pdfs/v60/Add_Terminate_Instructions.pdf. In addition, is a link to video instructions for Plaintiff to view on how to Add Terminate Party https://www.ilnd.uscourts.gov/Videos.aspx?folder=_cmecf&play=Add_Terminate.mp4. Plaintiff should file a status report by 2/22/24. Mailed notice.

PRELIMINARY INJUNCTION ORDER Signed by the Honorable Mary M. Rowland on 1/22/2024. Mailed notice.

NEW PARTIES: Bengbu Lucky Gifts Co., Ltd., Changsha Dongguan Packaging Products Co., Ltd., Dongguan Ione Technology Co., Ltd., Dongguan Play Together Toys Co., Ltd., Dongguan Qunyi Technology Co., Ltd., Dongguan Smart Gifts Co., Ltd., Dongyang Chenchen Jewelry Factory, Ezhou Tongguodou Trading Co., Ltd., Foshan Hengyue Outdoor Products Co., Ltd., Foshan Shengchi Trading Co., Ltd., Fuzhou Xuance Trade Co., Ltd., Guangxi Wuming Creative Technology Co., Ltd., Guangzhou Huanlin Trade Co., Ltd., Guangzhou Nuowei Toy Factory, Guangzhou Songdi Trade Co., Ltd., Guangzhou Wansha Industrial Holding Co.,ltd, Guangzhou Yuexiu District Ali Trading Firm, Hebei Wangjing Trading Co., Ltd, Hefei ZY Trade Co., Ltd., Quanzhou Furuntiancheng Clothes & Shoes Co., Ltd., Shenzhen Yingyan Trading Co., Ltd., Xiamen Nianxiang Trading Limited Company, Yangzhou Shanhai Gift Co., Ltd., Yanshan County Chujiu Trading Co., Ltd., Yichun Daotian Technology Co., Ltd., Yiwu Cassue Trading Co.,Ltd, Yiwu Jiaohao E-Commerce Firm, Yiwu Xiangchen Crafts Factory, Yiwu Yixin Silicone Products Co., Ltd., Zhengzhou Linqin Trading Co., Ltd., -Naughty baby Store, Anime planet Store, Bandai Clothes 01 Store, Bandai Figure Toy Store, CHEN-F-COS Store, FuBao-Toys Store, O-party Store, One Of Us Store, Open Sesame Children Clothes Store, Shop1102681813 Store, Shop1102924096 Store, Shop1102938184 Store, Shop1102993141 Store, Shop1103025220 Store, Shop1103067173 Store, Shop1103115060 Store, Shop1103203308 Store, Shop1103230078 Store, Shop1103295148 Store and Shop1103317316 Store added to case caption. Terminating The Partnerships and Unincorporated Associations Identified On Schedule A (Text entry; no document attached.)

NEW PARTIES: SOWXOF Clothing Store, Super Mario Store, Takara Tomy Peripheral Store, Wheat Juice Store, Yoo s Toy Store Store, Smart Heller Lee, Yaoyu123, 1Dreamer, AncientGreenStone, Arthink(2 weeks deliveried), Asmao332, Awaiymi Dekeliy US, bangjun INC, bbdiiieie, BOYUE INC, BYGO TECH, Cartoon Store USA, Changsha Chenpeng Department Store, Changsha Lvzujia Electronic Commerce Co., Ltd., Chen li shang, chengduhuangongchenkejiyouxiangongsi, ChloehloeShop, Contistano, Cutset-shop, ding2016jianhua, DIyou, Dolium, DUCHANGXIANMINGMUBAIHUODIAN, fan004Xruonan, FENGSH, FoShanShiXiaoLeiHaoTingMaoYiYouXianGongSi, FUNNWISH EDU, guangzhouhudaoshangmaoyouxiangongsi, Hantian store, hefeimaopiaofandianzishangwuyouxiangongsi, hefeisunliandianzishangwuyouxiangongsi, high quality child hat shop, HitchX, Hq1i8n0gT8RS0m5o9uQ, HuangMingJieAnQingPiaoJiangShangMao, hubeishenghaijishangmaoyouxiangongsi, Jessica and Jack's Shop, jiangdianmiss, Jieyunda, JiHaiWangLuoKeJi, jinanshilaiwuquxiaoyangfuzhuangdian, JINGWEEN, KENZOY, KGLBOY, KickKi Store, KXJFC, LANSUONI, lclrypd, libeiton, lijiahuibaihuodian8756, Lin canquan, LiuRong2042, liyichuandedian, lizhodng, lvxinglongoz1, mai0630chengji, MICOMESCE, nhuidianqiy, NX1102, Oilcookies, Poyntershop and Pupa Xiaofa Trading Co., Ltd added to case caption. (Text entry; no document attached.)

NEW PARTIES: A3OZ7SRZKF9QNR, PVATBL_Store, Qingzhi(2 weeks deliveried), RenYuChuanMei, ROOGMING, SAMGAN, SONGfang, suna98, Sunday Apparel, TeFangMaoYiYouXianGongSi, Terri Hinchey, TianShun987, TTFVNG, TTXXYY, wangbin123t, wangyingyingsssssssssssssss, Whou180032ZqianB, xie125220xue040612qi, xiongtingjun99, xysq, yangquanpingbindianzishangwuyouxiangongsi, Yeech88, YM J23.LLC, YO Toys store, YONGF, yu88yuan88fengbaihuodian, yuejintaodssd, YY-us, ZC-Forever, zhangchenyang56, zhanzhonghao, zhaotianyu, zlhcgd, ZQG-LLC, A1X8I37P8P43LW, Pinotoys, moderngraphx, ppenghappy99, starlightintelligent0, 3Decolor, DesignsbyConnar, Keebokunsart, Pinotoystore, PitayaCreativeStudio, Pablo Romero, Chengdukundimankedianzishangwuyouxiangongsi, Enstatie E-commerce (Haikou), Foshanshichanchengquhanchenhaibaihuoshanghang, Haikouzeyongshundianzishangwuyouxiangongsi, Lingshui Yan Yurong E-commerce, Shenzhenshi Lixin Maoyi You Xian Gong Si, Wanning Shajiangbin Network Technology, FurryMascot, baalency, Bedding Picky, BENSWTN, destinytextil, ebuycos, lucajackets, Luckyonesie, Magic plush, mitgardstore, musicdope80s, pazzale, PuppyPrinty, shopkalicloset, Toddlerme, Totalhill, westybedin, Arthur Rosenblum, Eric Perry, Marinesmall, Guangzhou British trading Co., LTD, Bihealth, Shenzhen Huanqi Tongda Technology Co., LTD, Shenzhen Xinghengchen e-commerce Co., LTD, shen zhen wan de feng raun zhuang she ji you xian gong si and congqiujifei added to case caption. (Text entry; no document attached.)

EMAIL from LDtailor dated 1/24/2024

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the email submitted by LDtailor on 1/24/24 [38]. Plaintiff is to communicate with LDtailor and file a status report by 2/22/24 updating the court on the status p the case and whether the dispute with the entities affiliated with LDtailor can be resolved. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

STATUS Report by Sega Corporation, Sega of America, Inc.

Exhibit A

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the status report [43]. Plaintiff shall file a status report by 3/29/24. Mailed notice.

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to certain Defendants

MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for entry of default, MOTION by Plaintiffs Sega Corporation, Sega of America, Inc. for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Sega Corporation, Sega of America, Inc. in support of motion for entry of default, motion for default judgment, [51]

Exhibit 1

Exhibit 2

DECLARATION of Martin F. Trainor regarding memorandum in support of motion[52]

Exhibit 1

STATUS Report by Sega Corporation, Sega of America, Inc.

Exhibit A

NOTICE of Voluntary Dismissal by Sega Corporation, Sega of America, Inc. as to a certain defendant

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion for entry of default and default judgment [51] is granted. Enter Final Judgment Order. Civil case terminated. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Mary M. Rowland on 4/10/2024. Mailed notice.

MAILED trademark report with certified copies of orders dated 4/10/24 to Patent Trademark Office, Alexandria VA.

FULL SATISFACTION of Judgment as to a certain defendant

FULL SATISFACTION of Judgment as to a certain defendant

FULL SATISFACTION of Judgment as to a certain defendant