2024-cv-01319

COMPLAINT filed by Sharp Shirter, Inc.; Jury Demand. Filing fee $ 405, receipt number AILNDC-21645952.

Exhibit A to Complaint

Exhibit B to Complaint (Part 1)

Exhibit B to Complaint (Part 2)

(Schedule A to Complaint)

SEALED DOCUMENT by Plaintiff Sharp Shirter, Inc. -- (Unredacted) Complaint

Exhibit A to Complaint

Exhibit B to Complaint (Part 1)

Exhibit B to Complaint (Part 2)

(Exhibit B to Complaint (Part 3))

SEALED DOCUMENT by Plaintiff Sharp Shirter, Inc. -- Schedule A to Complaint

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Sharp Shirter, Inc.

CASE ASSIGNED to the Honorable Elaine E. Bucklo. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (Civil Category 3).

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.

EX PARTE MOTION by Plaintiff Sharp Shirter, Inc. to File Under Seal

SEALED MOTION by Plaintiff Sharp Shirter, Inc. for Temporary Restraining Order, including a Temporary Injunction, a Temporary Asset Restraint, Expedited Discovery and Service of Process By E-Mail And/Or Electronic Publication

Memorandum in Support of Motion

Declaration of Dan Lachman

Declaration of Mackenzie Paladino

(Exhibit 1 to Declaration of Mackenzie Paladino)

MINUTE entry before the Honorable Elaine E. Bucklo: Parties to take note of Judge Bucklo's motion call practice posted on her page at www.ilnd.uscourts.gov. Counsel is directed to comply with Local Rule 83.15; designation of local counsel must be made within 30 days. Plaintiffs' motion for leave to file under seal 6 ; Plaintiff's Ex Parte motion for entry of a temporary restraining order, including a temporary injunction, a temporary asset restraint, expedited discovery, and service of process by email and/or electronic publication 7 are granted. Enter Sealed Temporary Restraining Order. Because the temporary restraining order will expire on 4/10/2024 any motion for preliminary injunction or to extend the temporary restraining order must be filed by no later than 4/8/2024. Doniger / Burroughs 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 5/10/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 5/3/2024 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 3/27/2024. Mailed notice.

CIVIL BOND in the amount of $ 10,000 posted by Sharp Shirter, Inc. (Document not Scanned).

NEW PARTIES: CREATIVE ART PRINT, Zowep, YEEWOOKA, SwordFir6, Differn158, Yzkj, ZKQQSM, SiC US, Simsant, Howilath-US, chuanhuiquhaoshuang88, PosterEnvy, Atrippy, LARTEEN, BYHH, Simpkeely, FangZZ, Shanxizhuoyuchengdianzik, Cyibiby, Adicreat, Chiinvent US, Guy Morant, Gonqtoz Art, Tiitstoy, NEWISTAR, LZTENRETO, Z0ZaZaZo Art & Design, Sikez, Snatelows, NTETSN, Blueplus, Jetai, KAPUCTW, Sunidoor, Landebaihuo, Ambola, UNICEU, Quanzhoushihuaicongwangluokejiyouxiangongsi, Aflycatus, UHOMETAP, kunmingmikuishangmaoyouxiangongsi, Yomiafy, Wpcheng, TYTYUU, Belovedtee, Asibeiul, PadPadStore, Quanhoushikehuanwangluokiyouxiangongs, HQER, Uideazone, Taole-US, Getelinfushimaoyi, Anhuai Flags, Sunaei, quanzhoubaoweixieyeyouxiangongsi, XINGHUOLIAOYUAN, WH 50 LLC, Haima Pretty, Guangzhoushidongyikeji, Avinyl (Home Dcor), KGJJIFILOO and Huafish added to case caption.

Response re Designation of Local Counsel by Sharp Shirter, Inc.

EX PARTE MOTION by Plaintiff Sharp Shirter, Inc. to Extend Temporary Restraining Order Deadlines

(Declaration of Mackenzie Paladino)

ATTORNEY Appearance for Defendants Adicreat, Aflycatus, Belovedtee, Blueplus, NEWISTAR, Sunidoor, Uideazone by David Silver

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 26, 29 only

MINUTE entry before the Honorable Elaine E. Bucklo: Parties to take note of Judge Bucklo's motion call practice posted on her page at www.ilnd.uscourts.gov. Plaintiff's Ex Parte motion to extend the temporary restraining order 12 is granted to 4/24/2024. Mailed notice.

MOTION by Defendants Adicreat, Aflycatus, Belovedtee, Blueplus, NEWISTAR, Sunidoor, Uideazone for hearing Opposition to Motion to Extend TRO 12 and Request for Hearing

SUMMONS Issued as to Defendant The Partnerships and Unicorporated Associations Identified in Schedule A

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 10, 56, 37, 38, 52, 55 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendants #48, 24, 42, and 54 only

SUMMONS Returned Executed by Sharp Shirter, Inc. as to Adicreat on 4/18/2024, answer due 5/9/2024; Aflycatus on 4/18/2024, answer due 5/9/2024; Ambola on 4/18/2024, answer due 5/9/2024; Anhuai Flags on 4/18/2024, answer due 5/9/2024; Asibeiul on 4/18/2024, answer due 5/9/2024; Atrippy on 4/18/2024, answer due 5/9/2024; Avinyl (Home Dcor) on 4/18/2024, answer due 5/9/2024; BYHH on 4/18/2024, answer due 5/9/2024; Belovedtee on 4/18/2024, answer due 5/9/2024; Blueplus on 4/18/2024, answer due 5/9/2024; CREATIVE ART PRINT on 4/18/2024, answer due 5/9/2024; Chiinvent US on 4/18/2024, answer due 5/9/2024; Cyibiby on 4/18/2024, answer due 5/9/2024; Differn158 on 4/18/2024, answer due 5/9/2024; FangZZ on 4/18/2024, answer due 5/9/2024; Gonqtoz Art on 4/18/2024, answer due 5/9/2024; Guangzhoushidongyikeji on 4/18/2024, answer due 5/9/2024; Guy Morant on 4/18/2024, answer due 5/9/2024; HQER on 4/18/2024, answer due 5/9/2024; Haima Pretty on 4/18/2024, answer due 5/9/2024; Huafish on 4/18/2024, answer due 5/9/2024; Jetai on 4/18/2024, answer due 5/9/2024; KAPUCTW on 4/18/2024, answer due 5/9/2024; KGJJIFILOO on 4/18/2024, answer due 5/9/2024; LARTEEN on 4/18/2024, answer due 5/9/2024; Landebaihuo on 4/18/2024, answer due 5/9/2024; NEWISTAR on 4/18/2024, answer due 5/9/2024; NTETSN on 4/18/2024, answer due 5/9/2024; PadPadStore on 4/18/2024, answer due 5/9/2024; PosterEnvy on 4/18/2024, answer due 5/9/2024; Shanxizhuoyuchengdianzik on 4/18/2024, answer due 5/9/2024; SiC US on 4/18/2024, answer due 5/9/2024; Sikez on 4/18/2024, answer due 5/9/2024; Simpkeely on 4/18/2024, answer due 5/9/2024; Simsant on 4/18/2024, answer due 5/9/2024; Sunidoor on 4/18/2024, answer due 5/9/2024; SwordFir6 on 4/18/2024, answer due 5/9/2024; TYTYUU on 4/18/2024, answer due 5/9/2024; Taole-US on 4/18/2024, answer due 5/9/2024; UHOMETAP on 4/18/2024, answer due 5/9/2024; Uideazone on 4/18/2024, answer due 5/9/2024; WH 50 LLC on 4/18/2024, answer due 5/9/2024; YEEWOOKA on 4/18/2024, answer due 5/9/2024; Z0ZaZaZo Art & Design on 4/18/2024, answer due 5/9/2024; ZKQQSM on 4/18/2024, answer due 5/9/2024; Zowep on 4/18/2024, answer due 5/9/2024; chuanhuiquhaoshuang88 on 4/18/2024, answer due 5/9/2024; kunmingmikuishangmaoyouxiangongsi on 4/18/2024, answer due 5/9/2024.

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to DOE 21 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to DOE #32 only

STIPULATION and [PROPOSED] Order Modifying TRO as to Certain Defendants only

MOTION by Plaintiff Sharp Shirter, Inc. to withdraw SEALED Order 9 as to Defendants No. 6 and No. 43 only

MOTION by Plaintiff Sharp Shirter, Inc. for preliminary injunction

Memorandum in Support of Motion

(Declaration of Mackenzie Paladino)

NOTICE of Motion by Mackenzie Paladino for presentment of motion for preliminary injunction 24 before Honorable Elaine E. Bucklo on 4/25/2024 at 09:45 AM.

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #60 Avinyl only

MINUTE entry before the Honorable Elaine E. Bucklo: Defendants Adicreat, Blueplus, Sunidoor, Aflycatus, Belovedtee, NEWISTAR, and Uideazone request for hearing 16 is granted. An in-person Status hearing set for 5/3/2024 at 10:00 a.m. Plaintiff's withdrawal of Ex Parte Temporary Restraining Order as to Defendant No. 6 "Yzkj" and No. 43 "Wpcheng" 23 is granted. Plaintiff's motion for entry of preliminary injunction 24 is granted. Enter Preliminary Injunction Order. The Clerk of Court is directed to unseal the following sealed documents: SHARP SHIRTER's Pleading(s) 2 and Exhibits A and B thereto, Schedule A to the Pleading(s) 3, Motion for Leave to File Under Seal 6, Motion for Temporary Restraining Order and all Supporting Documents thereto 7, TRO 9, and Motion to Extend the TRO 12. Status hearing previously set for 5/10/2024 and its status report are stricken. Mailed notice.

PRELIMINARY INJUNCTION Order signed by the Honorable Elaine E. Bucklo on 4/25/2024. Mailed notice.

ATTORNEY Appearance for Defendants Adicreat, Aflycatus, Belovedtee, Blueplus, NEWISTAR, Sunidoor, Uideazone by Joseph Wendell Droter

Request to Continue Status Conference or Appear Telephonically by Sharp Shirter, Inc.

(Declaration of Mackenzie Paladino)

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendants No. 45 and 51 Only

MINUTE entry before the Honorable Elaine E. Bucklo: Plaintiff's request to continue status conference 30 is granted. The in-person Status hearing is reset for 5/8/2024 at 10:00 a.m. Mailed notice.

ATTORNEY Appearance for Plaintiff Sharp Shirter, Inc. by Trevor William Barrett

MINUTE entry before the Honorable Elaine E. Bucklo: Pursuant to Stipulation and Order, the in-person status hearing set for 5/8/2024 is stricken. Enter Stipulation and Order Modifying Preliminary Injunction Order as to Certain Defendants. Status hearing set for 6/10/2024 at 9:45 a.m. (to track the case only, no appearance is required). By 6/3/2024 plaintiff is to file a status report as to non-dismissed defendants 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.

STIPULATION and ORDER Modifying Preliminary Injunction Order as to Certain Defendants signed by the Honorable Elaine E. Bucklo on 5/7/2024. Mailed notice.

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #36 Ambola only

ANSWER to Complaint with Jury Demand by Adicreat, Aflycatus, Belovedtee, Blueplus, Sunidoor, Uideazone

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 2, 6, 17 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to DOEs 9, 30, 40, 44, 58 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to DOE #18 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #25 Newistar only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #13 Atrippy only

STATUS Report by Sharp Shirter, Inc.

(Exhibit 1)

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #16 Simpkeely only

MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed the joint status report. Status hearing is reset for 7/23/2024 at 9:45 a.m. as to remaining non-dismissed defendant. (to track the case only, no appearance is required). The parties shall file a joint written status report by 7/16/2024. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #23 Gonqtoz Only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 4, 62 only

STATUS Report by Sharp Shirter, Inc.

(Exhibit 1)

MINUTE entry before the Honorable Elaine E. Bucklo: The Court adopts the report of parties planning meeting as to Represented Defendants. Parties are given to and including 8/2/2024 to amend all pleadings and to add any additional parties. Fact discovery ordered closed by 12/3/2024. Plaintiff shall comply with FRCP 26(a)(2) by 2/3/2025. Defendant shall comply with FRCP 26(a)(2) by 3/19/2025. All expert discovery to be completed by 4/18/2024 Dispositive motions with supporting memoranda due by 2/3/2025. Status hearing set for 10/10/2024 at 9:45 a.m. as to all remaining defendants (to track the case only, no appearance is required). The parties shall file a joint written status report by 10/3/2024. The court will enter a scheduling order in response to the status report. Mailed notice.

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 39, 5, 57 only

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant Nos. 20, 31, 34, 45, 50 only

STATUS Report by Sharp Shirter, Inc.

`MINUTE entry before the Honorable Elaine E. Bucklo: The Court has reviewed plaintiff's status report. Plaintiff will move for default judgment against remaining defendant(s). Status hearing is reset for 12/10/2024 at 9:45 a.m. (to track the case only; no appearance is required). The plaintiff shall file a written status report by 12/4/2024. The court will enter an order in response to the status report. Mailed notice.

EXECUTIVE COMMITTEE ORDER: GENERAL ORDER 24-0032: IT APPEARING THAT, the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable April M. Perry; therefore IT IS HEREBY ORDERED that the attached list of 290 cases be reassigned to the Honorable April M. Perry; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable April M. Perry's webpage on the Court's website for the purpose of reviewing instructions regarding scheduling and case management procedures; and IT IS FURTHER ORDERED that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new district judge for twelve months from the date of this Order; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable April M. Perry to the Court's civil case assignment system during the next business day, so that she shall receive a full share of such cases; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable April M. Perry to the Court's criminal case assignment system ninety (90) days so that Judge Perry shall thereafter receive a full share of such cases. Case reassigned to the Honorable April M. Perry for all further proceedings. Honorable Elaine E. Bucklo no longer assigned to the case. Signed by Honorable Virginia M. Kendall on 11/26/2024.

MINUTE entry before the Honorable Elaine E. Bucklo: This case has been reassigned to the Honorable April M. Perry. Therefore, in light of the reassignment, all pending dates before this court are stricken. Parties to take note of Judge Perry's standing order posted on her page at www.ilnd.uscourts.gov. Mailed notice.

MINUTE entry before the Honorable April M. Perry: This case having been recently reassigned to Judge April M. Perry, the Plaintiff is asked to file an Initial Status Report for Reassigned Cases by 12/20/2024. The required contents of the report may be found on Judge Perry's website at www.ilnd.uscourts.gov. Mailed notice. (jcc,)

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Defendant #12 Only

STATUS Report by Sharp Shirter, Inc.

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 Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MINUTE entry before the Honorable April M. Perry: Plaintiff's last status report, filed 12/20/2024, informed the Court that Plaintiff would be filing a motion for default against Defendants "in short order." No motion for default has been filed. Plaintiff is asked to file an updated status report by 3/17/2025. Mailed notice. (jcc,)

NOTICE of Voluntary Dismissal by Sharp Shirter, Inc. as to Certain Defendants only

MOTION by Plaintiff Sharp Shirter, Inc. for default judgment as to Defendant No. 14 LARTEEN

MEMORANDUM by Sharp Shirter, Inc. in support of motion for default judgment[62]

DECLARATION of Trevor W. Barrett regarding motion for default judgment[62]

Exhibit 1

NOTICE of Motion by Trevor William Barrett for presentment of motion for default judgment[62] before Honorable April M. Perry on 4/1/2025 at 10:00 AM.

MINUTE entry before the Honorable April M. Perry: Plaintiff's motion for default judgement [62] is taken under advisement. Plaintiff's motion for default judgement will be heard on 4/1/2025, at 10:00 a.m. in person in Courtroom 1725. Plaintiff must serve a copy of this minute order upon Defendant within three business days of its entry on the docket and promptly file proof of that service. Mailed notice. (jcc,)

CERTIFICATE of Service by Trevor William Barrett on behalf of Sharp Shirter, Inc. regarding order on motion for default judgment, terminate hearings, set motion and R&R deadlines/hearings, [66]

MINUTE entry before the Honorable April M. Perry: Per request, counsel for plaintiff shall appear at the hearing scheduled for 4/1/2025 at 10:00 a.m. by calling the Toll-Free Number: 650-479-3207, Access Code: 2307 684 8339. Members of the public and media will be able to call in to listen to this hearing (use toll free number). Please be sure to keep your phone on mute when you are not speaking. 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. (jcc,)

MINUTE entry before the Honorable April M. Perry: Motion hearing held on 4/1/2025. No one appears for Defendants. Plaintiff's motion for default judgment [62] is granted for the reasons set forth in Plaintiff's motion and in Court and consistent with the order to follow. Any further motion for costs and fees is due by 4/15/2025. Plaintiff must also file by 4/15/2025 a status update as to whether any defendants remain pending in this action, or whether the case may be terminated once the default judgment order is entered as to Defendant No. 14 LARTEEN. Mailed notice. (jcc,)

STATUS Report by Sharp Shirter, Inc.

FINAL DEFAULT JUDGMENT ORDER. Signed by the Honorable April M. Perry on 4/15/2025. Civil case terminated. Mailed notice. (jcc,)

MINUTE entry before the Honorable April M. Perry: The ten thousand-dollar ($10,000) surety bond posted by Sharp Shirter is hereby released to Trevor W. Barrett of Doniger/Burroughs. The Clerk of the Court is directed to return the surety bond previously deposited with the Clerk of the Court to Trevor W. Barrett of Doniger/Burroughs, 603 Rose Avenue, Venice, CA 90291 via certified mail. Mailed notice. (jcc,)

MAILED original ten-thousand-dollar ($10,000) surety bond posted by Sharp Shirter, Inc. to counsel of record for Plaintiff, Trevor William Barrett, Doniger / Burroughs Pc, 603 Rose Avenue, Venice, CA 90291, via certified mail # 9589 0710 5270 0579 7837 76.

RETURN of U.S. Post Office Receipt, article no. 9589 0710 5270 0579 7837 76.