2024-cv-03016

COMPLAINT filed by EnchantedMob, Inc., Mob Entertainment, Inc.; Filing fee $ 405, receipt number AILNDC-21857032.

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

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

CASE ASSIGNED to the Honorable Franklin U. Valderrama. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. 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.

MINUTE entry before the Honorable Franklin U. Valderrama: On or before 07/02/2024, the Parties shall file a joint initial status report. A template for the Joint Initial Status Report, setting forth the information required, may be found at http://www.ilnd.uscourts.gov/Judges.aspx by clicking on Judge Valderrama's name and then again on the link entitled 'Joint Initial Status Report. Plaintiff must serve this Minute Entry on all other parties. If the defendant(s) has not been served with process by that date, plaintiff's counsel is instructed to file an individual status report indicating the status of service of process by the same deadline. The parties are further ordered to review all of Judge Valderrama's standing orders and the information available on his webpage. Any nongovernmental corporate party that qualifies under the Rules is reminded of the requirement to file a disclosure statement under Federal Rule of Civil Procedure 7.1/N.D. Ill. Local Rule 3.2. Mailed notice.

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[12]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

DECLARATION of Zach Belanger regarding memorandum in support of motion[13]

Exhibit 1

Exhibit 2

Exhibit 3

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Exhibit 4 - Parts 1-10 regarding declaration[15]

SEALED EXHIBIT by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. Exhibit 4 - Part 11 regarding declaration[15]

MEMORANDUM by EnchantedMob, Inc., Mob Entertainment, Inc. Establishing that Joinder is Proper

DECLARATION of Justin R. Gaudio regarding memorandum[18]

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

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[20]

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion[21]

Exhibit 1

Exhibit 2

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motions, the Court grants Plaintiff's motion for leave to file under seal [3], ex parte motion for a temporary restraining order [12], and motion for electronic service of process [20]. Provided that Plaintiff provides the security described in paragraph 9 of the temporary restraining order, the temporary restraining order shall become effective on 4/25/2024 at 6:00 p.m. and shall expire in fourteen (14) days from the effective date. The Court finds that joinder of the "Schedule A" Defendants is proper at this preliminary stage. Fed. R. Civ. P. 20(a)(2)(A). The Court notes that no Defendants are prejudiced by permitting joinder at this juncture. See Bose Corp. v. Partnerships & Unincorporated Associations Identified on Schedule "A", 334 F.R.D. 511, 517 (N.D. Ill. 2020). To the extent any defendant appears and objects to joinder, the Court will revisit the issue and is free to sever certain defendants from the case under Rule 21 at that time. Mailed notice.

SEALED TEMPORARY Restraining Order. Signed by the Honorable Franklin U. Valderrama on 4/22/2024. Mailed notice.

Registry Deposit Information Form by EnchantedMob, Inc., Mob Entertainment, Inc.

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

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[26]

Declaration of Kahlia R. Halpern

Exhibit 1

SUMMONS Returned Executed by EnchantedMob, Inc., Mob Entertainment, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/6/2024, answer due 5/27/2024.

Declaration of Quinn B. Guillermo

Exhibit A

MINUTE entry before the Honorable Franklin U. Valderrama: On the grounds set forth in the motion, Plaintiff's motion for an entry of a preliminary injunction against Defendant Nos. 16-115 [26] is granted. Enter Preliminary Injunction Order. The following documents are to be unsealed: (1) Schedule A to the Complaint [2]; (2) Exhibit 4 to the Declaration of Zach Belanger [16], [17]; and (3) the TRO [24]. Counsel for Plaintiff is ordered to add ALL Defendant names listed in the Schedule A to the docket within three business days. Mailed notice

PRELIMINARY INJUNCTION ORDER signed by the Honorable Franklin U. Valderrama on 5/7/2024. Mailed notice

NEW PARTIES: Guangzhou Huilin Trading Co., Ltd., Hangzhou Sine Textile Co., Ltd., Jinhua Hairong Import And Export Co., Ltd., Quanzhou Liai Maternal And Child Products Co., Ltd., Shenzhen Hechun Technology Co., Ltd., Shenzhen Tuoyi Electronic Commerce Co., Ltd., Shenzhen Xuanlemen Technology Co., Ltd., Wuhan Wuchang Canada Electronic Business Firm, Yangzhou Creative Toys And Gifts Co., Ltd., Yangzhou Shanhai Gift Co., Ltd., Yiwu Chenchen Toy Factory, Yiwu Wopu Toy Co., Ltd., Yiwu Xitang Textile Co., Ltd., Zhejiang Multistay Industry Co., Ltd., Zhengzhou Yeahgo Trade Corporate Limited, A lucky dog, A11LROEC4WY6S8, A2P3LWLEYA85MC, A2T6DYA6SKTJ62, A2XEPX5YSIZZKJ, A2YU20Q5NTJV2K, A2ZU277FQOKAW3, A2ZUZBMNKVUBLH, A38AG1X37MYG7D, A3H4XEIR9TGL5Z, A3P939SP67VKNS, Alisasha, AO SABER, AQOBZMU, AVOS9T1X4HXBD, AZ7QH1OHV26J5, BAIYADASFSF, BOCHUNMY, BOYUU, Bright Wo., cekaishangmao, ChenJinUS, Chenzf shop, chongqingzhishudalixinxikejiyouxiangongsi, CRAVEFER-US, Cretlity Store, cuijunjieamz, Cutleeks, Daisiruina, DEATU 20% - 30% Off, dongliang-Z, EGNIAN, fall clothes for women 2023, Fengxi Optimization, Fengyuan Trade, fssqingping, Fun Lettered Sweatshirt, funToyland, gao yuansm, gaoguanglong, GongzwShop, GoodeCN Trade, Gou Tai., GRHZGF, Groydbee, Guanggaochuanmei, guangzhoubaoyaoshangmaoshanghanggerenduzi, hageme, haoetcw, Happy Shopping a, hejinshizhanghanshangmaojingyingbu, hengleishop, HJWShop, HOILCSIY, hongganshangmaoshanghang, iCODOD, ILLUMLOVE Direct, Jiarijiakeji, jinangushengxinxikejiyouxiangongsi, JINNIND, JinShanWuJinJingYingBu, JisooMiss, JIXiang9, JXTDZSW, K N T., KAIHSD, Kangxiaobin, Kawabuge, KISS KITTY-US, KJHUHDS, LaiDeLiang, lanliyun, laohekoushijiyadianzishangwugongzuoshi, LBAYOHO, LBJYSM, Lebowski & Co. STORE, liangchenshipin, liaolongxiangdedian, Liaoruay, LiJiaYi123, linbinshangmao, liyongcom, Lluary, LuckyYuear, Luminary You, MAying, moonon, NanPingShiYanPingQuChangFengKeJiYouXianGongSi, NANWANG, nationaa, neheshijucairiyongbaihuoshangdian, niubali, papei in pink, PixieFun, QEELINBO SHOP, qianjiexintu, qiaolian-l, QingHeXianAoYingMaoYiYouXianGongSi, Qinruishop and Quanzhoushiweiteerdianzishangwuyouxiangongsi 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 EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendant

SUMMONS Returned Executed by Mob Entertainment, Inc., EnchantedMob, Inc. as to The Partnerships and Unincorporated Associations Identified on Schedule A on 5/30/2024, answer due 6/20/2024.

Declaration of Quinn B. Guillermo

(Exhibit A)

ATTORNEY Appearance for Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. by Jennifer Van Nacht

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendants

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, [42]

Exhibit 1

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

Exhibit 1

ATTORNEY Appearance for Defendant Cutleeks by Adam Edward Urbanczyk

MOTION by Defendant Cutleeks for extension of time

MINUTE entry before the Honorable Franklin U. Valderrama: For the reasons stated in the motion, the Court grants Defendant Cutleeks' motion for extension of time to respond to the Complaint [46]. Defendant Cutleeks' responsive pleading is due by 7/15/2024. Mailed notice.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court grants Plaintiff's Motion for Entry of Default and Default Judgment [42] as modified. Enter Default Judgment Order. By 7/22/2024, Plaintiff is directed to file a status report as to the status of the case against the remaining defendants. To obtain release of the bond previously posted in this action, Plaintiff's counsel must file a motion for the return of the bond once the preliminary injunction no longer applies to any Defendant. Mailed notice.

DEFAULT JUDGMENT ORDER: Signed by the Honorable Franklin U. Valderrama on 6/25/2024. Mailed notice.

FULL SATISFACTION of Judgment regarding order[49] in the amount of $200,000 as to certain defendants

STATUS Report (Joint) Pursuant to [11] by EnchantedMob, Inc., Mob Entertainment, Inc.

MINUTE entry before the Honorable Franklin U. Valderrama: The Court is in receipt of the parties' joint initial status report [51], which indicates that the parties have reached an agreement and are currently executing the settlement agreement. Parties are directed to file a notice of dismissal by 8/30/24. Mailed notice.

NOTICE of Voluntary Dismissal by EnchantedMob, Inc., Mob Entertainment, Inc. as to certain defendant

STATUS Report Pursuant to [48] by EnchantedMob, Inc., Mob Entertainment, Inc.

MINUTE entry before the Honorable Franklin U. Valderrama: Before the Court is Plaintiff's status report [54], which notifies the Court that there are no remaining Defendants in the case and that the case may be terminated. Accordingly, the ten thousand dollar ($10,000.00) bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606. Enter Order. Civil case terminated. Mailed notice.

MAILED Trademark report with certified copy of minute order dated 07/26/2024 to Patent Trademark Office, Alexandria, VA.

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendant

FULL SATISFACTION of Judgment regarding order 49 in the amount of $200,000 as to certain defendant

MOTION by Plaintiffs EnchantedMob, Inc., Mob Entertainment, Inc. for Release of Bond

ORDER TO RELEASE BOND TO PLAINTIFFS: For the reasons stated in the motion, the Court grants Plaintiffs' motion for release of bond [60]. The ten thousand dollar ($10,000.00) bond posted by Plaintiff, including any interest minus the registry fee, is hereby released to Justin R. Gaudio of Greer Burns & Crain Ltd. The Clerk of the Court is directed to return the bond previously deposited with the Clerk of the Court to Justin R. Gaudio of Greer Burns & Crain Ltd., 300 South Wacker Drive, Suite 2500, Chicago, IL 60606. Enter Order. Signed by the Honorable Franklin U. Valderrama on 8/22/2025. Mailed notice.