2024-cv-02206

COMPLAINT filed by BBC Studios Distribution Ltd; Filing fee $ 405, receipt number AILNDC-21754853.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Schedule A regarding complaint[1]

MOTION by Plaintiff BBC Studios Distribution Ltd for leave to file under Seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by BBC Studios Distribution Ltd

Notice of Claims involving Trademarks by BBC Studios Distribution Ltd

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Justin R. Gaudio

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Rachel S Miller

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Jennifer Van Nacht

CASE ASSIGNED to the Honorable Manish S. Shah. Designated as Magistrate Judge the Honorable Sunil R. Harjani. 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.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

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

MOTION by Plaintiff BBC Studios Distribution Ltd for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for temporary restraining order[13]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Diane Hamer regarding memorandum in support of motion[14]

Exhibit 1

Exhibit 2

SEALED EXHIBIT by Plaintiff BBC Studios Distribution Ltd Exhibit 3 - Parts 1-9 regarding declaration[16]

MOTION by Plaintiff BBC Studios Distribution Ltd for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for miscellaneous relief[18]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[19]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 3 13 18 are granted. 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. The court finds that security in the amount of $50,000 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 3/26/2024. Notices mailed.

SURETY BOND in the amount of $ 50,000 posted by BBC Studios Distribution Ltd. (Document not Imaged)

MOTION by Plaintiff BBC Studios Distribution Ltd for extension of time of Temporary Restraining Order

MEMORANDUM by BBC Studios Distribution Ltd in support of extension of time 24

(Declaration of Rachel S. Miller)

NOTICE of Motion by Justin R. Gaudio for presentment of extension of time 24 before Honorable Manish S. Shah on 4/9/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time [24] is granted. The TRO is extended to 4/23/24. No appearance on 4/23/24 is necessary. Notices Mailed.

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

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Andrew Daniel Burnham

MOTION by Plaintiff BBC Studios Distribution Ltd for preliminary injunction as to Certain Defendants

(Exhibit A)

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for preliminary injunction 29

Declaration of Andrew D. Burnham

(Exhibit 1)

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for preliminary injunction 29 before Honorable Manish S. Shah on 4/23/2024 at 09:45 AM.

(Exhibit A)

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/18/2024, answer due 5/9/2024.

Declaration of Jennifer V. Nacht

(Exhibit A)

ATTORNEY Appearance for Plaintiff BBC Studios Distribution Ltd by Luana Faria De Souza (Faria De Souza, Luana)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction [29] is granted. 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 4/23/2024. Notices Mailed. (Main Document 35 replaced on 4/23/2024).

NEW PARTIES: Acki (Shenzhen) Holding Co., Ltd., Foshan Keyi Color Printing Co., Ltd., Quanzhou Kiara E-Commerce Co., Ltd., Shenzhen Hemu'an Technology Co., Ltd., Sichuan Shark Castle Trading Co., Ltd., Taizhou Shinywell Tech Co., Ltd., Yangzhou Shunyu Arts And Crafts Co., Ltd., Yiwu Jianjia Pet Products Co., Ltd., Yiwu Jinbiao Textile Co., Ltd., Yiwu Qiaomao Garment Co., Ltd., Yunnan Ming lun Import and Export Co.,Ltd, A359D0DKQJD8S3, A3JSSV8DD1455I, ADZZNISD8BED6, AprioriErb, AZU7EHE3OVLDZ, cangjinklong, Charmella, chongqingranhaowenjuyongpinyouxiangongsi, CloeStore, DaLiangBinZhouDianZiShangWuYouXianGongSi, DaTong - US, Dkibtol, Dreamy Baby Direct, dungthuy, GuangZhouShiShiYaJinMaoYiYouXianGongSi, guchengxianmeilianshangmaoyouxiangongsi, guchengxianqudaishangmaoyouxiangongsi, haikoumaidinaimaoyiyouxiangongsi, haikoumaoguweimaoyiyouxiangongsi, haikoumuweiguomaoyiyouxiangongsi, haikouwangzeweimaoyiyouxiangongsi, Happy Costume, heruobingdianzishangwuyouxiangongsi, HolidaySale, HU1YONGHONG, Huaduo Store, huangfeng888, jiujiangweigongkeshangmaoyouxiangongsi, Jumilia Global, KeWenQiang store, KunMingWuHuaXuDiKaiShangMaoYouXianGongSi, lehoudianzishangwuyouxiangongsi, LHLSPSTORE, Li Jinqiao, lianchengxianmeiyingxiashangmaoyouxiangongsi, liqiangkuajingbeimei, liuyifange, LQIANGG, maguihededian, Mei Lan Store, Mrs.HaLAn Store, NANRUIDA, NanYangZeLeWangLuoKeJiYouXianZeRenGongSi, NICORIYU, NORMOCARES, P0ret, PEngxuefenggongsi, pingdingyileibaihuoshanghang(gerenduzi), pinghaodianzishangwuyou, Sannesh, SHUNSHUNLE, shuyue-us, suhaodedian, suhuamaoyiyouxiangongsiguangzhou, Toysfeifei, Vieyiuls, Wang Ziqi, WITTRENDSN, wqydd, WSND88, WU1XIAOFENG, wwxxfff, Wycheng, xingzhi-us, XTDSMSH, xuehaoyundianzishangwuyouxiangongsi, xxx.xxx2, YANG1XIUHUAN, YangJiangShiJiangChengManQiaTaiShangMaoXing, yangquanyizhongshangmaoyouxiangongsi, Yutong shop, Zhanggg, zhangjiakang, Zhijiang Tuanbi Trading, a9005, a903, a904, cartonn, downjacket993, earthcn, laekjh, mling1, mling2, psize, umcrph, w00010, w0005, waql and yyddww added to case caption.

SUMMONS Returned Executed by BBC Studios Distribution Ltd as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/24/2024, answer due 5/15/2024.

Declaration of Jennifer V. Nacht

Exhibit A

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendant

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendant

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to certain defendants

NOTICE of Voluntary Dismissal by BBC Studios Distribution Ltd as to a Certain Defendant

MOTION by Plaintiff BBC Studios Distribution Ltd for entry of default as to all Defendants, MOTION by Plaintiff BBC Studios Distribution Ltd for default judgment as to all Defendants

Exhibit A

MEMORANDUM by BBC Studios Distribution Ltd in support of motion for entry of default, motion for default judgment, [42]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[43]

Exhibit 1

NOTICE of Motion by Andrew Daniel Burnham for presentment of motion for entry of default, motion for default judgment, [42] before Honorable Manish S. Shah on 5/22/2024 at 09:45 AM.

MINUTE entry before the Honorable Manish S. Shah: Hearing on 5/22/24 at 9:45 a.m. on plaintiff's motion for entry of default judgment [42] will be held in Courtroom 1725. Notices Mailed.

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for entry of default judgment 42 granted. Enter Default Judgment Order. Civil case terminated. Notices Mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 5/22/2024. Notices Mailed.

FULL SATISFACTION of Judgment regarding order[48] as to certain defendant

MAILED trademark report with certified copy of minute order dated 5/22/2024 to Patent Trademark Office, Alexandria VA. (jn,)

FULL SATISFACTION of Judgment regarding order[48] in the amount of $50,000 as to certain defendant (Faria De Souza, Luana)

NOTICE of withdrawal of bond [23] by John Summerfield (bi,)